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.