Privacy Statement

This Privacy Statement tells you how we protect and use information that we gather through Medtronic Mobile Applications (the "Application" or "App"). This Privacy Statement is intended for a global audience.

For users in Europe, please refer to the privacy statements specific to your geography that are referenced in your App.

This Privacy Statement was last revised April 2022. We may change the Privacy Statement at any time and for any reason.

Please read the End User Licensing Agreement (EULA) for your Application to understand the general rules about your use of the Application. Except as written in any other disclaimers, policies, terms of use, or other notices in an Application, this Privacy Statement and the EULA are the complete agreement between you and Medtronic with respect to your use of the Application.

Introduction

The Applications are owned and operated by Medtronic. Medtronic is the name we use to refer to our whole business, including Medtronic plc. and any of the companies that it controls, such as its subsidiaries and affiliates. When we use the words "we" or "our," we mean Medtronic. The information we receive, and how we use it, depends on what you do when using the Application.

We collect and use both personal information (information that is identifiable to you personally) and non-personal information about you through the application. Please see below for a definition of personal and non-personal information, and how Medtronic may use them. Please also refer to additional privacy statement language below specific to users in the European Economic Area.

What is personal information?

Personal information is information we collect through the App that can specifically identify you. Personal information that may be processed through the App include:

How does Medtronic collect and use your personal information?

We may collect and use personal information from you through the App to provide you with access to the App. You may choose not to provide us with this information, but then you may not be able to access and utilize the App. In addition, we may collect and use your personal information:

Please also see additional privacy statement language below specific to users in the European Economic Area.

Does Medtronic ever share personal information with third parties?

Medtronic will not share your personal information collected from the App with an unrelated third party without your permission, except as described below. Medtronic may share personal information with any member of our corporate group, including parent companies, subsidiaries, and affiliates, for purposes that are consistent with those identified in this Privacy Statement.

In the ordinary course of business, we will share some personal information with companies that we hire to perform services or functions on our behalf. In all cases in which we share your personal information with a third party, we will only allow them to keep, disclose, or use your information to provide the services we asked them to provide. We will not sell, exchange, or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition.

We may be required to release your personal information in response to a court order, subpoena, search warrant, law, or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting Application users who violate our rules or engage in behavior which is harmful to other users (or illegal). In addition, we may keep, disclose, and use your personal information in order to comply with U.S. FDA and other governmental guidance, directions, regulations, and laws.

We may disclose your personal information to third parties if we feel that the disclosure is necessary to:

Transfers between countries

What is non-personal information?

Non-personal information is information we collect through the Application that does not identify you as an individual. It may include information such as the following:

What does Medtronic do with non-personal information?

Because non-personal information cannot identify you, there are no restrictions on the ways that we can use or share non-personal information. We will use non-personal information to help us make the App more useful to users. We also will use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:

 

How can I delete my MCL-H account?

You may ask for the deletion of your account by going to the Profile screen under Menu and following the steps after tapping "Delete MyCareLink Heart Account." Your personal and non-personal data as described above will be deleted from the MCL-H mobile application. The personal and non-personal data previously transmitted to your CareLink account will not be deleted from CareLink Network by this action. WARNING: DELETING YOUR ACCOUNT IN THIS MANNER WILL STOP TRANSMISSION OF YOUR HEALTH DATA TO YOUR HEALTH CARE PROVIDER AND CONSEQUENTLY STOP REMOTE MONITORING BY YOUR HEALTH CARE PROVIDER. For this reason, Medtronic strongly encourages you to work with your Health Care Provider prior to deleting your MCL-H account.

In some exceptional instances, personal data may be retained if required to enable use to comply with the legal requirements, including compliance and record retention regulations.

 

What about privacy on other applications?

The Application may contain links to other apps or websites. Some of those websites or apps may be operated by Medtronic, and some may be operated by third parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites or apps operated by others. This Privacy Statement does not apply to any other application or website, even if operated by Medtronic. We are not responsible for the performance of applications or websites operated by third parties or for your business dealings with them. Therefore, whenever you leave the Application we recommend that you review each application or website's privacy practices and make your own conclusions regarding the adequacy of these practices.

Does Medtronic ever communicate directly with users to the application?

We may contact you periodically by email or text messages, if you agree to that. If you have push notifications enabled, you may receive notifications for MCL-H functional purposes.

 

Cookies

Apps that link to, or connect with, websites may include cookies, pixel tags/web beacons, and similar technologies. This helps us to provide you with a good experience when you use the App or browse the websites, and also helps us to improve the App and our website. For further detailed information about cookies and the purposes for which we use them, please see the section of our website privacy policy that discusses cookies, above.

Children’s privacy

We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child's name or email address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us. For Middle East and North Africa users, please notify us regarding children under the age of 18.

California " Do not track " disclosures

California law (CalOPPA) requires Medtronic to let you know how we respond to web browser "Do Not Track (DNT) signals." Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not honor Do Not Track requests at this time.

What about application security?

Security is very important to us. We also understand that security is important to you. 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 online database or Internet transmission is ever 100% secure or error-free. You acknowledge that the App may not be password protected, and that you are responsible for maintaining the confidentiality and security of any of your data available via the App on your mobile device, by using an ID and password credentials for your mobile device.

How to contact Medtronic

If you have questions or comments about this Privacy Statement, please use the Contact Us form on our App, or use the  Contact Us  form on our website.

You may use the Contact Us form on our Application to exercise your rights to access, rectify, update, and/or eliminate your personal information or ask for non-disclosure. Elimination may not be possible if it can cause damage to third parties or if preserving your personal information is required by any law or regulation.

 

Disclaimer: This page may include information about products that may not be available in your region or country. Please consult the approved indications for use. Content on specific Medtronic products is not intended for users in markets that do not have authorization for use.


 

For Users in the European Economic Area

Introduction

We, Medtronic, would like to provide you with information on how your personal information will be processed when you use this application.

We work with your medical institution for the provision of the Medtronic CareLink Network Services for the remote monitoring of your device and health data where personal information is retrieved from your implanted cardiac device and processed on the Medtronic Carelink Network. We process your personal information on behalf, and upon instruction, of your medical institution. You have been informed by your health care professional about the processing of your personal information with regard to the use of the Medtronic CareLink Services. What has been explained to you, also applies to the data processed by this application. 

In addition, the application allows you to collect certain data that will remain on your device only and will not be sent to the Medtronic CareLink Network, and therefore will not be processed by your medical institution or Medtronic.

How does Medtronic keep and use personal information?

Legitimate Interests

When we process your personal information 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 information for the following purposes, based on legitimate interests:

Legal Rights and Obligations

We may also process your personal information on the basis of our legal right or obligation to do so in order to:

Consent

We may also process your personal information for other purposes for which you have specifically given consent, i.e. to conduct patient satisfaction surveys to measure your user satisfaction and general sentiment of app features which may include processing of health-related data in a de-identified manner. To the extent that we conduct such patient satisfactions surveys including health-related data, we will only do so on the basis of your consent, in accordance with applicable laws. You may withdraw your consent at any time by contacting us as set out here above under " How to contact Medtronic " . Note that this does not affect the lawfulness of our use of your personal information before you withdrew your consent. Also, aggregated data which we have already compiled will not be affected, even after you withdraw your consent, as there are no technical means available to isolate or identify data elements to exclude.

 

How can I delete my MCL-H account?

 

If you have questions on the processing of your personal information using this application, please contact your health care professional directly.