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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.
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.
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.
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.
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:
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:
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:
Consent: We may also process your Personal Data for other purposes for which you have specifically given Consent. Such purposes may include:
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.
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 firstname.lastname@example.org
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 email@example.com
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:
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.
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.
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 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: firstname.lastname@example.org. 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.
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
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.