Personal data at Medtronic

This section describes how Medtronic uses your personal data to provide you with therapies and related services. Unless we need your personal data in order to comply with laws and regulations, you are not required to provide information to us but, if you choose not to do so, we may not be able to offer you certain services and related features, or to respond to requests that you may have.

Account management

We may collect and process your personal data to create and manage your account with us, or when you request information about therapies or related services.

Types of personal data

• Credentials. Username, password, authentication/verification codes, and account verification questions/answers.
• Contact information. Name, email address, postal address, telephone number, geographic location, language, date of birth, communication preferences, and optional profile pictures and third-party login information.
• Family information. Marital status, family and household contact, relationship, and health data, dates of birth and death, legal guardianship, emergency contact status and information, and names and contact information of authorized persons named by you.
• Device/network information. Your device, browser, and operating system version and type, device identifiers, IP address, authentication data, and your interactions with our services, including timestamped logs of resources requested, accessed, and interacted with.

Purposes of use

• Creating and maintaining your account, including through verifying your contact and authentication information through welcome communications.
• Authentication.
• Registering your device.
• Recording your preferences, including for communications from us.
• Authorizing your delegates/emergency contacts to access your account as needed.

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Communicating with you about your treatment

We may collect and process your personal data to communicate with you about your treatment, including at your request.

Types of personal data

• Contact information. Name, email address, postal address, telephone number, geographic location, language, date of birth, communication preferences, and optional profile pictures and third-party login information.
• Family information. Marital status, family and household contact, relationship, and health data, dates of birth and death, legal guardianship, emergency contact status and information, and names and contact information of authorized persons named by you.
• Information about your medical device or treatment, including device identifiers and your health data related to treatment.

Purposes of use

• Recording your preferences, including for communications from us.
• Registering your device.
• Communicating with you about your condition or treatment, including information about your condition, treatment, or device pre- and post- trial and permanent implant.
• Communicating with you about your device, including notifications about device configuration and status, as well as safety or quality issues if they arise.
• Fulfilling your requests for information from us.

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Providing treatment to you

We may collect and process your personal data to treat and care for your medical condition and device.

Types of personal data

• Contact information. Name, email address, postal address, telephone number, geographic location, language, date of birth, communication preferences, and optional profile pictures and third-party login information.
• Family information. Marital status, family and household contact, relationship, and health data, dates of birth and death, legal guardianship, emergency contact status and information, and names and contact information of authorized persons named by you.
• Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.
• Your medical device treatment history, including implantation details.
• Your medical record and history, including your conditions, general health status, disabilities, family medical history, sex/gender, age, prescriptions and medications, procedure information (including IDs, videos, duration, and dates), medical practitioners, and lab/telemetry results.
• Your medical status, including vitals, symptoms, condition reports, image, and device telemetry/monitoring.
• Volunteered information, including communications you send to us or other data you choose to provide.

Purposes of use

• Recording your preferences, including for communications from us.
• Registering your device.
• Communicating with you about your condition or treatment, including information about your condition, treatment, or device pre- and post- trial and permanent implant.
• Monitoring your device, including for issues with and the efficacy of the device or your health or condition.
• Communicating with you about your device, including notifications about device configuration and status, as well as safety or quality issues if they arise.
• Servicing your device, including by updating or upgrading it, diagnosing and resolving issues, and optimizing its configuration.
• Improving our treatments, products, and services, such as through surveys about specific health conditions or device performance/feedback.
• Fulfilling your requests for information from us.

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Coordinate treament with your care team

We may collect, process, and disclose your personal data to coordinate and work with your care team to treat and care for your medical condition and device.

Types of personal data

• Contact information. Name, email address, postal address, telephone number, geographic location, language, date of birth, communication preferences, and optional profile pictures and third-party login information.
• Family information. Marital status, family and household contact, relationship, and health data, dates of birth and death, legal guardianship, emergency contact status and information, and names and contact information of authorized persons named by you.
• Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.
• Your medical device treatment history, including implantation details.
• Your medical record and history, including your conditions, general health status, disabilities, family medical history, sex/gender, age, prescriptions and medications, procedure information (including IDs, videos, duration, and dates), medical practitioners, and lab/telemetry results.
• Your medical status, including vitals, symptoms, condition reports, image, and device telemetry/monitoring.
• Volunteered information, including communications you send to us or other data you choose to provide.

Purposes of use and disclosure

• Coordinating with your care team when you request an appointment with a health care practitioner who will be treating your condition or managing your device, including your implanting and continuing care physicians.

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Accounting and payment processing

We may collect and process your personal data for accounting and payment purposes.

Types of personal data

• Contact information. Name, email address, postal address, telephone number, geographic location, language, date of birth, communication preferences, and optional profile pictures and third-party login information.
• Health payer and claims information, including information on your provider, health condition and services rendered, health payer and your group, subscriber, account/member, and similar numbers or identifiers, claims history, financial assistance data, invoices, receipts, and payment information.

Purposes of use and disclosure

• Submitting to your care provider or payer for payment for your health care services and products.
• Accounting activities, including audits, investigations, insurance requirements, and general bookkeeping.

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Analysis, research, and development

We may collect and process your personal data for research and development purposes, such as improving the quality, safety, and efficacy of devices, services, interfaces, and treatments.

Types of personal data

• Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.
• Your medical device treatment history, including implantation details.
• Your device/networking information, including system generated user ID, system log including system events and error logs, machine data, system configuration, system generated procedure ID, device ID, other data collected during your interaction with our therapies or related services, and date and time stamps.

Purposes of use

• Analysis, including event and crash detection, repair, and improvement, and utilization and efficacy reviews.
• Research, including activities resulting from that research such as developing and improving programs, therapies, related services, and content.

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Marketing material

We may collect and process your personal data for marketing purposes where you have provided your agreement.

Types of personal data

• Contact information. Name, email address, postal address, telephone number, geographic location, language, date of birth, communication preferences, and optional profile pictures and third-party login information.
• Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.
• Customer data, such as transaction, payment, and contract data.
• Professional status, including employment-related data and affiliations.
• Volunteered information, including communications you send to us or other data you choose to provide.

Purposes of use

• Fulfilling your requests for information from us.
• Assessing the performance of our marketing, including analytics about your use of our services and interactions with us and improving the efficacy of our communications.
• Contacting you with information that may be of interest, including, as permitted by law, information about clinical trials, educational events, therapies, new devices, or other offerings.

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General

The data collected, discussed in the preceding sections, may be used for Medtronic’s general business purposes, including:

• To fulfil our contract with you when it is our legal duty.
• When it is in our legitimate interest to:
  • Manage the security of websites, networks, systems, and services Medtronic provides to our customers.
  • Manage websites for healthcare professionals, account access support, verify your personal identity as needed for us to provide our therapies or related services, online support, and related services safely and lawfully.
  • Properly administer our business, therapies or related services.
  • Manage our relationship with you and keep our records up to date.
  • Support and manage our therapies or related services by our service providers and/or business partners.
  • Enforce this Privacy Notice and other rules about your use of our product or services.
• With your consent, where required by law or when it is in our legitimate interest to:
  • Ensure our organization runs properly.
  • Protect our organizations systems and software including your personal data.
  • Understand how to improve our therapies or related services.
  • Provide you extended warranty on selected therapies or related services.

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Sensitive data use

Some of the data we collect and use is considered sensitive under applicable laws, which may include, for example, health- and financial-related data and genetic/biometric data. Our collection and use of sensitive personal data is limited to that which is necessary to provide you with your requested services, including treating your condition. You can choose to withdraw or withhold your consent, but, because your sensitive data is necessary to provide you with these services, you will not be able to use these services.

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Data you provide to us

We may ask that you, your caregiver, your account administration, or any individual authorized by you not to send or disclose any other personal data other than the data that we ask you to provide using our therapies, related services or otherwise to us.

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Telephonic contact

By disclosing the phone number(s) you provide to Medtronic, we may contact those number(s), including via text, SMS, or voice call, for the transactional purposes defined in this Privacy Notice, as well as for responding to requests you make of Medtronic. If you provide an additional consent for marketing communications, Medtronic may then contact you by telephone for marketing, advertising, or offers of sale of Medtronic therapies or related services as well.

When making contact by telephone, Medtronic may use automated technologies (including recordings and auto-dialing), and telephone, airtime, message, and data rates may apply. By providing your phone number(s) and/or consent(s), you certify that (a) you are age 13 and older, (b) the contact information you provide is yours, and (c) you authorize and consent to use of the information provided for Medtronic to contact you. Consent is not a condition for purchase or services. You may opt out of telephonic contact from Medtronic using automated technologies and for marketing communications at any time by (i) texting "STOP" in reply to a text message or (ii) for marketing messages, signing into your Medtronic profile and updating your communication preferences.

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