PRIVACY STATEMENT

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY

Scope

This website and this Privacy Statement are intended for Singapore, Thailand, Vietnam, Indonesia, Malaysia, the Philippines, Brunei, Myanmar, Cambodia, Laos, and Mongolia (collectively the “Southeast Asia”) audience.

For Australia and New Zealand: Please visit our ANZ Privacy Policy which applies to our interactions with you.

For Japan: Please visit our Japan Privacy Policy which applies to our interactions with you.

For South Korea: Please visit out South Korea Privacy Policy which applies to our interactions with you.

For India: Please visit out India Privacy Policy which applies to our interactions with you.

Introduction

Medtronic in Southeast Asia (hereinafter referred to as “we, us, our and Medtronic”), are bound by the privacy principles under the laws, regulations and codes of each of the countries mentioned above. The object of this privacy statement (“Privacy Statement”) is to protect the confidentiality of Personal Data and the privacy of individuals by regulating the way in which Personal Data is managed.

We respect your (‘your‘ or ‘you’ shall mean the party disclosing Personal Data) privacy and want you to be familiar with how we process your Personal Data (refer to definition section). This Privacy Statement describes our practices in connection with information that we collect from you through this website as well as mobile sites, applications, widgets, conferences, events, electronic newsletters communications or other services (collectively the “Services”) that provide a link to this Privacy Statement. We are not responsible for the privacy practices of any third-party websites that may be linked on our website.

This Privacy Statement does not apply when we process information:

• about our employees and business consultants in the scope of their employment or business consultancy relationship with us, unless otherwise mentioned in the contracts entered into with our employees and business consultants.
• where we have given other disclaimers, policies, terms of use, or other notices indicating that this statement does not apply, or that a different privacy statement or notice does apply
• that does not identify you as an individual person, including to Personal Data (which we define below) or after any information that can no longer be used to identify you
• only as a processor of information on behalf of a third party where the processing is governed by separate terms

You should review the privacy statement posted on other Medtronic websites when you visit them. This website and this Privacy Statement are intended for Singapore, Thailand, Vietnam, Indonesia, Malaysia, the Philippines, Brunei, Myanmar, Cambodia, Laos, and Mongolia (collectively the “Southeast Asia”) audience.

We intend to deal with your information in a manner that is fair according to the laws and in line with your expectations and we encourage you to read and consider the information provided in this Privacy Statement to confirm that is the case.

Definitions

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

Personal data can include "health information", which refers to information regarding an individual's physical or mental health or a health service provided to an individual or "sensitive personal data", which includes information or an opinion about an individual's health, racial or ethnic origin, political opinions, philosophical criminal record and sexual orientation, amongst other things.

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

What Personal Data do we collect?

Medtronic collects Personal Data that is reasonably necessary for or directly related to our functions and services. Medtronic collects Personal Data from or about you when we ask you for it and you provide it, when it is provided to us by your healthcare professional, and also through technology that collects the information automatically, such as cookies or other similar technologies.

Medtronic may collect Personal Data in a variety of ways. For example:

• In some places on our website, you have the opportunity to send us Personal Data 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 websites, in which case we will ask you for certain Personal Data to make your visits to our web sites more helpful to you. When this information is combined with the non-Personal Data that we collect through cookies, we will be able to tell that you have visited our web sites before.
• We may collect Personal Data from you when you contact us for information on Medtronic products, services, or product complaints.
• We may collect Personal Data about you in the course of engaging in commercial transactions with our customers, vendors, and other business contacts

Personal data may be collected by Medtronic in the course of:

• Providing technical assistance about our products to a patient or healthcare professional
• Responding to product or service queries
• Sales calls or follow-up meetings with our sales representatives
• Participation in Medtronic sponsored programs, including educational programs and research grants
• Using our websites, apps, product information or other services, including through use of cookies

Where do we use your Personal Data?

Medtronic will use your Personal Data for the purpose for which it is collected, which generally includes the following purposes:

• During the sale, distribution or provision of medical devices, apps or services that have been requested by you or health care providers
• While supporting you and your healthcare professional or other care partners (as authorized by you) in your ongoing care, if you are a patient
• Administering training programs, clinical trials, or other similar programs in which you agree to be involved
• Compliance with regulatory requirements, such as maintaining a record of medical queries, complaints, adverse events, and recalls relating to our products

We may also use your Personal Data for the purposes listed below which include but not limited to:

• Provide you with updated product or safety information with respect to Medtronic medical devices, apps, and services
• Send you material on our activities and products or developments in medical technology that Medtronic believes may be of interest to you
• Respond to your requests for information, product, services including managing your online accounts and providing warranty service where this applies to products
• Provide you with general health information for educational purposes, where this is permissible, such as information about certain health conditions, as well as information about our products and services
• Resolve or track the status of issues raised by consumers on products or services
• Manage, plan, and arrange meetings between you and Medtronic representatives
• Generate customer lists for the purposes of market research
• Manage accounts and ensure that we receive payment for our products
• Verify your age or identity as needed for us to provide our products and services safely and lawfully
• Improve our products, services, and overall therapy management
• De-identify your information by removing all personal identifiers (your name, e-mail address etc.) so that the information is no longer Personal Data and can be used for other purposes
• Protect someone's health safety or welfare
• Comply with a law or regulation, court order or other legal requirement
• Undertake other activities for which you have consented we can use or disclose your Personal Data
• We will only use or disclose your Personal Data for a purpose that was not the primary purpose for which we collected it, if we are required, authorized or permitted by law or a court / tribunal order to do so.
• Sometimes we may collect sensitive Personal Data if you disclose it to us, or as part of providing services to you. When dealing with sensitive Personal Data, such as your health information, for a purpose that is not directly linked to the primary purpose of collection, Medtronic will generally seek your consent before using Sensitive Personal Data. In only very limited circumstances, such as where we are required by law to disclose information or in the event of a serious threat to your life or health, will we use or disclose your health information for other secondary purposes to the extent necessary in the circumstances without your consent.

Sharing and Disclosing your Personal Data with third parties

We may disclose Personal Data:

• To our group companies, related companies and affiliates
• To third party service providers engaged by us so that they may perform services for us or on our behalf
• To third party service providers engaged directly by your healthcare professional, so that they may perform services for your healthcare professional or on their behalf
• If you are a patient, to care partners who you nominate to receive information and notifications about you and your care from Medtronic
• Where we are authorized or required by law to do so or are permitted to disclose the information under the laws and regulation
• If you have expressly consented to the disclosure or consent may be reasonably inferred from the circumstances

If you do not wish to receive information or materials about Medtronic products and updates, you may request not to receive these marketing materials. Once Medtronic receives your request, we will add your name to a no contact list for marketing purposes.

Cross Broder Data Transfer

As part of a global group of companies located in many different countries, we may disclose your Personal Data to a Medtronic company or affiliate, or to our database or servers overseas which may be provided to us by our third-party service providers. In disclosing Personal Data offshore, Medtronic ensures that the use and disclosure of the Personal Information transferred is dealt with in accordance with this Privacy Statement and the requirements of applicable privacy laws.

How we protect your Personal Data

We use reasonable physical, administrative, and technical safeguards to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Access to the Personal Data is restricted to those employees and third-party service providers who need to use the data, who have been trained to handle such data properly and observe strict standards of confidentiality.

While Medtronic cannot guarantee against any loss, misuse, or alteration to data, we take security safeguards as are reasonable in the circumstances to prevent such occurrences. If you have a reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How you can contact us?” section below.  

Medtronic destroys or permanently anonymize Personal Data that we no longer need, where permitted.  Medtronic’s policy is to not keep Personal Data for longer than it is required for the purposes for which the information may be lawfully used or disclosed.   

Your rights and choices available to you

You have the right, in most cases, to access your Personal Data at any time. Medtronic takes reasonable steps to ensure that any Personal Data we hold about you is up-to-date, accurate, relevant, not misleading and complete. If you would like to submit a request to access, correct, update, restrict the processing, or delete your  Personal Data, or if you would like to request an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please send such requests by email to rs.datasubjectrightrequest@medtronic.com or by post to Attn: Data Protection Officer in your respective country.

There are some circumstances in which we are not required to give you access to your Personal Data.  Medtronic shall take such steps as are reasonable, to attach a statement provided by you to the information of the corrections sought. Medtronic may not accommodate a request to access, change or delete Personal Data if it believes doing so would violate any law or legal requirement, or cause the information to be incorrect. In those circumstances, if requested by you.If we have based our collection or use of your Personal Data 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.

How can you contact us?

If you have a complaint about how we have handled your Personal Data or have questions about this privacy statement, please contact us at rs.askdpo@medtronic.com

Updating our Privacy Statement

Medtronic may review or revise this Privacy Statement and the way we handle Personal Data from time to time. Such changes will be consistent with current privacy legislation in SEA Countries. We encourage you to review this Privacy Statement each time you visit the website. This Privacy Statement was last updated on April 6, 2022.