Privacy Statement

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.

INTRODUCTION

FOR INFORMATION ABOUT COOKIE USe, please continue reading.

This Privacy Statement describes how we process personal information that we collect about you through this website operated by Medtronic based in Canada (Medtronic Canada ULC, a Medtronic company), as well as mobile sites, conferences, events, electronic newsletter communications or other services (collectively the “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, nor does it apply to other Medtronic websites, including websites operated by other Medtronic affiliates, including Covidien and Medtronic MiniMed.  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 Canadian audience.

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:

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

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 any of its affiliates. When we use the words we or our, we mean Medtronic. In Canada, Medtronic is Medtronic Canada ULC.

WHEN DOes this privacy statement APPLY?

This Privacy Statement applies when we process personal information collected in Canada. These Privacy Principles apply to personal data when we collect it directly from the data subject (being the person who the data identifies), and also when we collect data from one person (or company or other legal entity) 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 Privacy Statement does not apply when we process information:

• 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.
• about our business consultants in the scope of their business consultancy 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 personal information (which we define below) or after any information has been anonymized, so that it can no longer be used to identify you
• only as a processor of information on behalf of a third party where that processing is governed by separate terms.

WHAT IS data PROCESSING?

Data processing is any operation or 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, disseminating, or otherwise making available, consulting, 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:

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

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 may also 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.

We may also use automated means to collect personal information about our users, specifically through cookies (see further).

HOW DOES MEDTRONIC PROCESS PERSONAL INFORMATION?

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:

• 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, sexual orientation, political opinion/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
• according to applicable laws which include suitable and specific measures to safeguard your fundamental rights and interests
• 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 Health Canada, 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 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 name of the domain from which you access the Internet
• The Internet Protocol address (“IP Address”) of the computer you are using
• The type of browser and operating system you are using The date and time you access our website
• The internet address of the site from which you linked directly to our website
• Which pages you have visited on our website (note: U.S. healthcare providers, please see the 'uses of personal information' described below)
• The 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.

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

WILL MEDTRONIC EVER USE PERSONAL INFORMATION TO CONTACT ME WITH MARKETING OR EDUCATIONAL MESSAGES?

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.

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.

SURVEYS

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 information 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 we believe also often benefit you.

The business purpose of collecting your data is to reply to survey feedback you may have provided, specifically:

• Should you have indicated an issue which we need to take action to resolve
• In order to gain further insight to the experience you have described
• To inform you of any action we might take internally to resolve your issue or enhance your experience

WHAT IF I NO LONGER WISH TO RECEIVE INFORMATION FROM MEDTRONIC?

If you wish to stop receiving 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 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.
• use a third-party application or platform to conduct surveys, which can include storage of the survey feedback.

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.

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 other country that is recognized by Canada as having adequate privacy protections. We will transfer information to other areas only in furtherance of the purposes set out in this Privacy Statement, namely 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 and Europe.

WHAT HAPPENS IF THE STATEMENT OF PRIVACY PRINCIPLES CHANGES?

This Privacy Statement was last revised on March 4, 2021. We encourage you to review this Privacy Statement each time you visit the website.  You can view the previous version of our Privacy Statement 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, that is the purpose for white we are allowed to use the information, as set out in this Privacy Statement. 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 taking into account the type of personal information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity. 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)).

We will continue to treat your personal information in accordance with this Statement of Privacy Principles so long as we retain it.

WHAT about privacy on other websites?

Links

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. 

Cookies.

 Medtronic may also use cookies, pixels, web beacons, and similar technologies (“cookies”), that work through placing a small file (like a text file or graphic) in the browser files of your computer when you visit. The cookie may be stored on your computer's hard drive. Cookies are used to collect information for business purposes, such as enabling essential website functions and improving the user experience. We use both session cookies and persistent cookies. You are free to decline our cookies if your browser permits, but some parts of our website may not work properly for you if you do so. Medtronic Diabetes may use third-party tracking and advertising providers to act on our behalf to track and analyze your usage of our sites. These third parties may collect, and share with us, as we may request, website usage information about visits to our sites, measure and research the effectiveness of our advertisements, and track page usage and paths followed during visits through our sites. Also, these third-party providers may place our Internet banner advertisements on other sites that you visit, and track use of our Internet banner advertisements and other links from our marketing partners' sites to our sites. To the extent the information collected on behalf of Medtronic Diabetes by these third parties contains any personally identifiable information, we will protect it in accordance with this privacy statement.

We will not allow third parties other than those companies that we hire to perform services or functions on our behalf to place cookies on our website. Please refer to your browser Help instructions to learn more about managing cookies You may opt-out of the use cookies through your internet browser’s plugins or privacy settings at any time, but this may impact the functionality of our website.

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 Privacy Statement, please contact us at:

OUR CONTACT INFORMATION IS:

Medtronic Canada ULC
99 Hereford Street
Brampton, ON
L6Y 0R3

Tel: 905-460-3800
Toll-free: 1-800-268-5346
Fax: 905-826-6620

Or here.

Version: March 2021