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This Privacy Statement tells you how we use information that we collect about you through this Medtronic website operated by Medtronic International Trading Sàrl based in Switzerland 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 Statment. 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 and Medtronic Minimed.
This Privacy Statment also does not apply to data processing activities specifically relating to current or former Medtronic employees or applicants. The relevant Employee Privacy Statement or Applicant Privacy Statement may be requested by contacting AskHR@Medtronic.com.
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 European 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.
The information we receive, and how we use it, depends on what you do when visiting our website or using our Services. 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:
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:
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:
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, phone number, 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 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 firstname.lastname@example.org.
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 was last revised on 10th June, 2019. 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. You can view the previous version of our Privacy Statement here.
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.
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”).
Medtronic International Trading Sàrl
Attn: Data Protection Officer
Route du Molliau 31
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.
Our Data Protection Officer may be contacted by email at rs.swissDPO@medtronic.com
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
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.