PLEASE READ THIS PRIVACY STATEMENT CAREFULLYThis Privacy Statement tells you how your local Medtronic entity (please see the list below) uses information about you that is collected through this Medtronic website. Medtronic values your business and has designed this statement to inform you of our information practices and policies regarding this Medtronic Discovery™ Link Clinician Website.
Please note that this Privacy Statement applies solely to the information which we gather through this website medtronicdiscoverylink.com ("Site") and does not apply to any other website operated by Medtronic or its affiliates, or any third party websites that we may link to. We encourage you to review the privacy statements posted on other Medtronic sites when you visit them. This Privacy Statement is only concerned with the collection and use by Medtronic of personal information on this Site when Medtronic is acting as a data controller (that is when Medtronic is determining why and how your personal information will be used). This Privacy Statement is not intended to inform patients of how patient personal information may be processed on the Site via the Discovery™ Link tool. If you are a patient, please refer to your treating physician for more information on that.
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.
Please also read our Terms and conditions of Medtronic CareLink Network Services Agreement (the "Agreement") to understand the general rules about your use of this Site.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
The information we receive, and how we use it, depends on what you do when visiting our Site. We collect and use non-personal information (information that does not identify you personally) differently to your personal information.
WHAT IS PERSONAL INFORMATION?
Personal information is information we collect through this Site that we can use to directly identify you, and includes specifically the following categories of information:
- name, address, or any contact informationname, address, or any contact information
- clinic name and address
- clinic telephone number
- clinic role (such as physician, nurse, administrator, etc.)
In addition, from time to time, Medtronic may request that you provide us with specific information on your practice generally, your experiences with patients that use a Medtronic CareLink Monitor, and your activities on this Site. This information is also personal information.
We collect personal information about our users in two ways:
- when you directly provide information to us, e.g. by entering personal information on certain pages of the Site, such as when you register for a Discovery™ Link account or contact us or send us feedback via a contact form on the Site.
- 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
WHAT DOES MEDTRONIC DO WITH PERSONAL INFORMATION?
We may keep and use personal information we collect from you through this Site to provide you with the requested access to this Site. In addition, we may keep and use your personal information to provide the services offered via the Site, including by responding to your requests expressed via the Site
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:
- to personalize your access to our Site, for example, by telling you about new features that may be of interest to you
- to ensure the proper functioning of the Site, including in any interactions between any devices, technology and infrastructure and the Site, through amongst others periodic maintenance, incident response, troubleshooting and technical support
- to create and evaluate aggregate data regarding the Site usage, based both on personal information and non-personal information, in order to be able to proactively optimize the Site
- to create and evaluate data obtained from incident response, troubleshooting and technical support for the Site, to improve the Site
- to contact you with information that might be of interest to you, including information about similar products and services of ours which are linked to the scope of the Site
- to evaluate the performance and use of the Site, or of any equipment, technology and infrastructure required to use the Site, in particular to identify areas of improvement which may contribute to the safety, security and quality of the services provided via the Site
- to take appropriate technical and organizational measures to ensure an appropriate level of security of the personal data processed; this may include pseudonymisation, anonymization and encryption.
- 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
- to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities, in which case the processing will be limited to what is minimally required to comply with the order
Where required by law, we will ask you to "opt-in" or affirmatively consent to the collection and use of your personal information for a particular purpose. For example, where the law so requires, we will only send you newsletters if you have subscribed to them.
Medtronic will collect and your information exclusively on the basis of your consent, in order to perform a service contract to which you are a party, based on a legitimate interest, in order to comply with or enforce a legal right or obligation, and to protect vital interests, as described above. Where processing is based on consent, you have the right to withdraw your consent at any time.
WHAT IS NON-PERSONAL INFORMATION?
Non-personal information is information we collect through this Site that does not directly identify you as an individual person. It may include specifically the following categories of information:
- the type of web browser software you use (for example, Internet Explorer or Netscape Navigator)
- the name of the domain from which you access the Internet
- the Internet address of the website from which you linked directly to the Site
- the date and time you access the Site
- which pages you have visited on the Site
Medtronic may collect non-personal information from you in two ways. First, we may collect certain information from your computer's web browser. In addition, we may also place a text file called a cookie in the browser files of your computer when you visit. A cookie is a numeric code that a website transfers to your hard drive for recordkeeping purposes
Should you wish to do so, your browser software can be set to reject cookies, including the cookies from our Site. Please note that if you reject all cookies, this Site may not be able to operate as intended.
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. We may also use non-personal information for other business purposes. Specifically, 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
- create statistical reports for internal use
- customize the information or services that are of interest to you on the basis of your non-personal information
- understand and improve the website's general performance
- understand and improve feature usage on the website
- discover broken links and UI bugs
- understand and improve user workflows
- understand and improve the origin of inbound referrals
- understand and improve what users are searching for on the site
- determine content relevancy
Any aggregate and statistical data created on the basis of your non-personal data may be shared with third parties. Note that third parties are also involved in the processing of information from cookies.
DOES MEDTRONIC 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 service providers that we hire to perform specific services or functions on our behalf, and/or with other Medtronic entities that are involved in providing the services offered through the Site.
For example, we may:
- use a service provider to administer certain aspects of the Site.
- 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
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 via the contact details set out below.
HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?
We will only keep your personal information for so long as necessary to fulfil 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 decide to discontinue the use of our Site and request that your account be deleted, we will delete any associated personal data which we have collected for the purpose of administering your account and will only retain your information for longer if we have lawful grounds to do so (e.g. if necessary for validation or to comply with recordkeeping obligations)).
WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?
If we decide to make a significant change to this Privacy Statement, we will provide a notice on the Site for a period of time after the change is made.
WHAT ABOUT PRIVACY ON OTHER WEBSITES?
This Site may contain links to other websites. Some of those websites may be operated by Medtronic, and some may be operated by third parties. We provide any links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. This Privacy Statement does not apply to any other website, even other Medtronic websites. We are not responsible for the performance of websites operated by third parties or for your business dealings with them. Therefore, whenever you leave this website we recommend that you review each website's privacy practices and make your own conclusions regarding the adequacy of these practices.
DIRECT MARKETING AND EDUCATIONAL MATERIALS
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.
WHAT ABOUT WEBSITE SECURITY?
We take reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
Your information will be retained by Medtronic for as long as you use the Site and any services related to the Site, or for as long as required for Medtronic to manage its legal responsibilities as governed by applicable law.
YOUR RIGHTS AND HOW TO CONTACT MEDTRONIC
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 email@example.com or in writing to the attention of the Data Protection Officer of your local Medtronic entity (address below). 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 us/our Data Protection Officer at firstname.lastname@example.org or the applicable Data Protection Authority. See further: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
List of Medtronic Entities
- Austria: Medtronic Oesterreich G.m.b.H., Handelskai 94-96, Wien
- Belgium: Medtronic Belgium S.A./N.V., Burgemeester Etienne De Munterlaan 5, Brussels
- Bulgaria: Medtronic Bulgaria EOOD, 48 Sitnyakovo blvd, Sofia
- Croatia: Medtronic Adriatic d.o.o., Folnegoviceva 1c, Zagreb
- Czech Republic: Medtronic Czechia s.r.o., Prosecka 852/66, Praha
- Denmark: Medtronic Danmark A/S, Arne Jacobsens Alle 17, Copenhagen
- Finland: Medtronic Finland Oy, LentÃ¤jÃ¤ntie 3, Vantaa
- France: Medtronic France S.A.S., 27/33 quai Alphonse le Gallo, Boulogne Billancourt
- Germany: Medtronic GmbH, Earl-Bakken-Platz 1, DÃ¼sseldorf, Meerbusch
- Greece: Medtronic Hellas Medical Device Commercial S.A., Kifisias Avenue 24, Maroussi
- Hungary: Medtronic Hungaria Kereskedelmi Kft, Bocskai ut 134-136, Budapest
- Ireland: Medtronic Ireland Limited, Unit Ga, Swords Business Campus, Co Dublin
- Italy: Medtronic Italia S.p.A., Via Varesina 162, Milano
- Netherlands: Medtronic Trading NL B.V., Larixplein 4, Eindhoven
- Norway: Medtronic Norge AS, Martin Linges vei 25, Fornebu
- Poland: Medtronic Poland Sp. z o.o., Polna 11 Street, Warsaw
- Portugal: Medtronic Portugal, Lda, Rua Tomas da Fonseca, Lisboa
- Romania: Medtronic Romania SRL, 42-44 Bururesti-Ploiesti Road, Building B, B2 Wing, 2nd Floor, Bucharest
- Slovakia: Medtronic Slovakia s.r.o., Karadzicova 16, Bratislava
- Slovenia: Medtronic, trgovina z medicinsko tehnologijo in opremo d.o.o., Ameriska ulica 008, Ljubljana
- Spain: Medtronic IbÃ©rica S.A., Calle Maria de Portugal, 11, Madrid
- Sweden: Medtronic Aktiebolag, P.O. Box 1034, Kista
- Switzerland: Medtronic (Schweiz) A.G. (Medtronic (Suisse) S.A.), Talstrasse 9, MÃ¼nchenbuchsee
- United Kingdom: Medtronic Limited, Building 9, Croxley Green Business Park, Watford