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Privacy Statement

This Privacy Statement tells you how we use information that we collect about you in relation to the consultancy, training and education 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. 

Introduction

Medtronic (hereinafter referred to as “we”) provides and facilitates consultancy, training, and education services delivered by and to healthcare professionals (hereinafter referred to as “you”), focusing on the safe and effective use of Medtronic products and services or specific to a disease or protocol (hereinafter referred to as “Services”). The Services may be delivered in-person or remotely, including through accessing or logging into a teleconferencing or learning management system provided by Medtronic or a third party engaged by Medtronic for this purpose. The systems and programs used to deliver the Services are hereinafter referred to as the “Platform”.

Some minimal personal information is typically collected in order to deliver these learning Services. We will Process your Personal Data, as strictly relevant to the provision of the Services. We understand that you are aware of and care about your own personal privacy interests and we take that seriously. This Privacy Statement describes Medtronic’s practices regarding its collection and use of your Personal Data and sets forth your privacy rights. We encourage you to read this Privacy Statement carefully.

Definitions

By ”Personal Data” we mean any information which relates to an identified/identifiable natural person, in other words, any information which can lead to knowing who you are (either directly or indirectly).

By “Processing” we mean any operation which is performed on Personal Data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restrictions, erasure or destruction.

By “Consent” we mean your freely given, specific, informed and unambiguous (not subject to misinterpretation or more than one interpretation) indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the Processing of your Personal Data.

By “Aggregated Data” we mean that data from different sources are combined to observe trends and patterns over a large population/group. By using a large population/group and deriving statistics from it, we minimise identification to unique individuals.

Personal data categories

For the provision of our Services, we may Process the following categories of Personal Data:

Contact and account details – when you register for the Services, we may collect Personal Data such as: first name, last name, email-address, postal address, profession, therapy group, primary medical specialty, hospital/clinic name, city, country of practice, access rights requested, username and password as needed for any Platform log-in. In case required by national law, physician number, nurses and allied professional number will be collected.

Training and education data – when you access the Services the following data may be collected and linked to you, including through the creation of a learning profile for this purpose: course attendance, learning program progress, assessment/observation results at single question level, course evaluation, course completion, certification, training exemptions, results of knowledge tests, learning modules and resources viewed, and feedback assessments.

Travel information - to organise and facilitate in-person training, events or meetings we may Process the following additional Personal Data needed for trip and event management purposes: national ID/passport number, dietary and travel preferences, logistics and travel details, expenses.

Trainer/Consultant Information – If you are engaged by Medtronic to provide the Services we may Process additional Personal Data in order to administer our contractual relationship, including basic identity information, contact details, professional activities and affiliations, professional qualifications, financial information on honoraria paid by Medtronic, and bank account information.

Images/Video/Audio – The delivery of the Services may involve photography or video recording by Medtronic, or make use of a Platform that will transmit your audio, video and/or image to other participants.  You will be informed if Medtronic intends to actually capture and record any such Personal Data for further use.

Additional Information – If you provide additional information such as personal preferences, we will process such data in accordance with this privacy statement. Medtronic may identify certain characteristics, preferences or traits on the basis of which we may create or compile professional, financial or behavioural profiles for the purposes mentioned below.

Purposes and legal basis for processing

Contract: We Process your Personal Data to provide the Services, based on your free choice to enroll / participate in our Services or your engagement with Medtronic to provide the Services. This serves as our contract with you or with the organisation on whose behalf you are engaged or subscribe/participate (hereinafter referred as a “Contract”) and such serves as our legal basis for Processing your Personal Data for the following purposes:

  • For the provision of the Services: to design and deliver the Services, to create and maintain your learning account, to create charts, tables and reports which can help you understand your progress through Medtronic learning pathways, to enable Medtronic to provide you with additional training and education content and other information to assist you with your training and education experience, to create and distribute Service deliverables (e.g. training materials and recordings, if applicable);
  • To facilitate event/training support: to communicate with you regarding the Services (including replying to your queries and questions), to provide you with notifications of event or training information (e.g. registration, schedule) and relevant follow up (surveys, thank you notes)

Legitimate Interests: When we Process your Personal Data for carefully considered purposes based on the legitimate interests of Medtronic or another party, we do so, based on our assessment that such legitimate interests do not override your data protection rights. We may Process your Personal Data for the following purposes, based on legitimate interests:

  • To get a better understanding of how effective our Services are;
  • To identify where our Services may require improvement;
  • To optimise the learning experience, by tracking and managing individual and account-based learning pathways and progress, and analysing such data within the Platform;
  • To measure event participation and effectiveness;
  • To analyse performance metrics and survey results, in order to improve training effectiveness;
  • To aggregate Personal Data to a level where you are no longer directly identifiable. Such information is used to create and communicate statistics on the general use of our Platform in order to:
    • Gain a better understanding about the use of our products and training and education services;
    • Measure expenditure on our training and education activities and face to face events per region/Business Unit, to better understand business needs and further develop our strategy;
    • Understand how training has been delivered within categories like medical specialty, country of practice;
    • To get better insights into the resources and costs associated with providing our Services;
  • To use imagery, audio or video footage from the Services for educational, promotional or other legitimate business purposes. In such circumstances Medtronic will take measures designed to reasonably protect your privacy rights. 

Legal Rights and Obligations: We may also process your Personal Data on the basis of our legal right or obligation do so in order to:

  • Comply with laws including those regarding transparency and the management of training on the safe and effective use of our products;
  • To track and manage compliance approvals and violations;
  • In the event of a legal claim: for the establishment, exercise or defence of a legal claim.

Consent: We may also process your Personal Data for other purposes for which you have specifically given Consent. Such purposes may include:

  • Use of your image or audio or video footage for educational, promotional, or other legitimate business purposes to which you specifically Consent (where such use is not already covered by the terms of your Contract);
  • Where Consent is required to send you communications regarding products or services that may be of interest (see further Marketing Communications below);
  • In case we need to process any sensitive Personal Data (such as health data) in connection with the Services, we will only do so on the basis of your explicit Consent.

Marketing Communications: to the extent that we send you communications regarding products and services that we believe may be of interest to you, we will only do so on the basis of legitimate interests or your Consent, in accordance with applicable laws. You may at any time opt-out of receiving such communications via the opt-out mechanism included in the relevant communication, or by Contacting Us as set out below. 

How long does Medtronic keep your personal data for?

Your Personal Data will only be retained by Medtronic for so long as necessary and relevant to fulfil the purposes set out herein and may be retained beyond the duration of your business relationship with Medtronic to enable us to fulfil such purposes and comply with legal requirements to demonstrate adherence to Medtronic’s obligation to manage training to Health Care Professionals for safe and effective use of our products.

For more information on where and how long your Personal Data is stored, please send an email to privacyeurope@medtronic.com

Cross border Data Transfer

Personal Data may be Processed by Medtronic and its affiliates, as well as its third-party service providers, contractors and consultants inside and outside the European Economic Area (EEA). When European Personal Data is transferred outside the EEA, UK or Switzerland, we use approved legal mechanisms, which may include standard data protection clauses (EU Model Clauses), to meet data protection laws and requirements. More details can be requested by sending an email to privacyeurope@medtronic.com

Data sharing

Certain components of the Platform are provided by third party providers. We may use third party service providers in order to achieve the purposes set out in this Privacy Statement including:

  • to deliver the Services through a Virtual Classroom, Teleconferencing or Learning Management System;
  • to manage our relationship and communications with you through Communications Tools and Customer Relationship Management Systems;
  • to effectively gather your feedback through a Survey Tool; and
  • to manage your registration and travel arrangements through an Event Management Tool.

We will enter into binding agreements with these service providers which include data processing clauses to ensure that your Personal Data is always Processed in accordance with applicable data protection laws and regulations.

In the event that you engage directly with a third party service provider outside the scope of the Medtronic Services (e.g. by interacting with their website or availing of additional services from them) please note that the third party’s own privacy statement will apply to any resulting Processing of your Personal Data.

Security of your personal data

Medtronic is committed to protecting the security and confidentiality of your Personal Data. We use technical and organisational measures designed to protect your Personal Data against unauthorised or unlawful destruction, loss, alteration, disclosure or access.

Your rights

Subject to applicable law, you may have the right to:

  • Request access to the Personal Data we have concerning you
  • Request rectification, erasure, or restriction of the Processing of your Personal Data (including deletion of your Learning Management account).
  • Object, based on your particular situation, to any use or Processing of your Personal Data which we have based on our legitimate interests;
  • Request your Personal Data in a structured, commonly used and machine-readable format (data portability)
  • If we use your Personal Data based on your Consent, you can withdraw your Consent at any time and discontinue the relevant data Processing activities. Note that this does not affect the lawfulness of Processing based on Consent before your withdrawal.

Please note that we may keep using Aggregated Data (statistics, trends), even after you request deletion of your Personal Data or withdraw your Consent, as there may be no technical means available to isolate or identify the data elements to exclude.

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: privacyeurope@medtronic.com. Please note that in accordance with applicable laws, we may ask you to provide some proof of identity 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. 

Contact

The Services are facilitated and carried out by the Medtronic entity identified in the Contract or other documentation provided in connection with the Services. Please note that in case the Services are provided through an engagement or collaboration with your institution or employer, then they may also be responsible (independently, or together with Medtronic) for the Processing of your Personal Data in connection with the Services, in which case your institution or employer should be your first point of contact in that regard. Medtronic’s EMEA Headquarters is located at

Medtronic International Trading Sárl
Route du Molliau 31
CH - 1131 Tolochenaz

Email privacyeurope@medtronic.com

This Privacy statement is published on May 15, 2020.

We recognise that data protection is an ongoing responsibility, so we will update this Privacy Statement in case we undertake new Personal Data practices or adopt new privacy policies.