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Privacy Statement

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.

INTRODUCTION

Privacy is very important to us. We also understand that privacy is very important to you. This Privacy Statement tells you how we protect and use information that we gather through this Medtronic website based in the United States. Medtronic and some of its affiliates, including Medtronic Minimed, and our international affiliates, also operate other websites. This Privacy Statement does not apply to the other Medtronic websites. 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 U.S. audience.

By using this website, you agree to the terms of the most recent version of this Privacy Statement. Please read our Terms of Use to understand the general rules about your use of this website. Except as written in any other disclaimers, policies, terms of use, or other notices on this website, this Privacy Statement and the Terms of Use are the complete agreement between you and Medtronic with respect to your use of this website. You may be subject to additional terms that may apply when you access specific services or materials on certain areas in this website, or when you follow a link from this website.

WHAT IS PERSONAL INFORMATION?

Personal information is information that we can use to specifically identify you, such as your:

Name
Address
Unique personal identifier (e.g., device ID, online identifier)
Internet Protocol address
Email address
Account name
for U.S. healthcare providers, a National Provider Identifier# (NPI) and/or a state license number
Social security number
Driver’s license number, or
Other similar identifiers
Characteristics of protected classifications under state/federal law (e.g., age, race, sex, medical condition, etc.)
Medical information
Health insurance information
Financial information, including credit card numbers
Biometric information (e.g., imagery of the iris, retina, fingerprint, face, or other data that contain identifying information)
Commercial information (e.g., purchase history)
Internet or other electronic network activity information (e.g., browsing history, interaction with our website, etc.)
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information (e.g., call recordings)
Professional, employment-related, or other similar information

In some places on this website you have the opportunity to send us personal information about yourself, to elect to receive particular information, or to participate in an activity. For example, you may fill out a registration form, a survey, or an e-mail form and you may elect to receive educational material about our products and therapies.

You also may choose to allow us to personalize your visits to the website, in which case we will ask you for certain personal information to make your visits to our website more helpful to you. When this information is combined with the information that we collect through cookies (described below), we will be able to tell that you have visited our website before and can personalize your access to our website, for example, by telling you about new features that may be of interest to you.

HOW DOES MEDTRONIC KEEP AND USE PERSONAL INFORMATION?

We may keep and use personal information we collect from you through this website to provide you with access to this website. In addition, we may keep and use your personal information:

to respond to your requests
to personalize your access to our website, for example, by telling you about new features that may be of interest to you
to develop records, including records of your personal information
to contact you with information that might be of interest to you, including information about clinical trials and about products and services of ours and of others
for analytical purposes and to research, develop and improve programs, products, services and content
for U.S. healthcare providers, to link your name, National Provider Identifier (NPI), state license number, and/or your IP address to web pages you visit, for compliance, marketing, and sales activities
to remove your personal identifiers (your name, e-mail address, social security number, etc.). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information.
to enforce this Privacy Statement and other rules about your use of this website
to protect someone’s health, safety or welfare
to protect our rights or property
to comply with a law or regulation, court order or other legal process

DOES MEDTRONIC EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

Medtronic will not share your personal information collected from this website with an unrelated third-party without your permission, except as otherwise provided 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. 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. In cases in which we share your personal information with a third-party, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

We may be legally compelled 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 website visitors who violate our rules or engage in behavior which is harmful to other visitors (or illegal).

We may disclose your personal information to third parties if we feel that the disclosure is 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
fulfill obligations relating to a corporate sale, merger, dissolution, or acquisition
comply with a law or regulation, court order or other legal process

Please note: In addition to the ways that we may keep, disclose, and use information described in this Privacy Statement, we also may keep, disclose, and use personal information in ways that we believe are consistent with FDA and other governmental guidance, directions, regulations, and laws, including HIPAA, where applicable.

COLLECTING ONLINE INFORMATION

If you visit our web site to read or download information, such as information about a health condition or about one of our products, we may collect certain information about you from your computer. This information is collected from your computer’s web browser. This information may include:

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 web site
The internet address of the site from which you linked directly to our web site
Which pages you have visited on our web site (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

Cookies: We also may collect this information through 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.

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 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 Medtronic’s behalf 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. And see below for an explanation of our use of cookies as well as how to opt out of our use of cookies.

CHOICES ABOUT COOKIES AND OPT-OUT OPTIONS

For more information on third-party advertising-related cookies and how to opt out of some cookies as you choose, see the descriptions and links below.

Click here to visit the Network Advertising Initiative site to set preferences and opt out of third-party targeting cookies.

EU visitors can find general information and opt-out resources at youronlinechoices.eu and US visitors can visit aboutads.info and allaboutcookies.org.

WHAT DOES MEDTRONIC DO WITH NON-PERSONAL INFORMATION?

Non-personal information is information that cannot identify you or be tied to you. We are always looking for ways to better serve you and improve this website. We will use non-personal information from you to help us make this website more useful to visitors. 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:

create reports for internal use to develop programs, products, services or content
customize the information or services that are of interest to you
share it with or sell it to third parties
provide aggregated information on how visitors use our site, such as ‘traffic statistics’ and ‘response rates,’ to third parties

HOW DOES MEDTRONIC PROTECT MY ACCOUNT INFORMATION? (ONLY APPLICABLE ON WEBPAGES OFFERING USER ACCOUNT LOGINS)

Certain of our webpages permit you to create a user account and login to that account. The information in this section applies to those webpages:

Viewing/Editing Personal Information: You may change the information you have provided by logging into your account and editing the information. If you are the patient, your personal information will be viewable by all persons you have invited and registered on your account (e.g., Friends and Family Members). If you are registered on a patient’s account, your personal information will be viewable by the patient as well as others registered on that account.

Storage of Personal Information: Medtronic may store your personal information on servers in countries where Medtronic operates, including a server(s) located in the United States of America. If you choose to close your account, we will maintain copies of your information in our internal records, systems, and databases, in accordance with our data retention schedules. We will continue to treat your personal information in accordance with this Privacy Statement.

Protecting Personal Information: We take security seriously and take a number of steps to protect your personal information. You also play a big part in protecting the privacy of your personal information. When you create an account, we ask you to select a password that is unique to you. To protect your personal information from unwanted disclosure, you should not give your password to anyone with whom you would not share your personal information. Our website may also log you out after a period of inactivity and require you to log in again. When you are ready to leave this website, always “log off” and close your browser to help protect the confidentiality of your information.

WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made. Significant changes are also described below.

Recent revisions to the Privacy Statement:

This Privacy Statement was last revised and the Supplemental Privacy Notice for California Residents was added on December 6, 2019. Our Privacy Statement was significantly expanded on October 31, 2001. You can read the previous version of our Privacy Statement here. In addition, we made minor revisions to the Privacy Statement in July 2008, April 2009, June 2013, September 2013, July 2014, and January 2015, but these revisions did not change the privacy principles.

WHAT ABOUT PRIVACY ON OTHER WEB SITES?

This web site may contain links to other web sites. Some of those web sites 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 web sites operated by others. This Privacy Policy does not apply to any other web site, even the other Medtronic web sites. We are not responsible for the performance of web sites operated by third parties or for your business dealings with them. Therefore, whenever you leave this website, we recommend that you review each website’s privacy practices and make your own conclusions regarding the adequacy of these practices.

DOES MEDTRONIC EVER COMMUNICATE DIRECTLY WITH VISITORS TO THIS WEBSITE?

We may contact you periodically by e-mail, mail or telephone if you agree to that contact to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this website allow you to communicate with us using an online form. If your communication requests a response from us, we will send you a response via e-mail. The e-mail response or confirmation may include your personal information, including personal information about your health, your name, address, etc. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.

ARE THERE SPECIAL RULES ABOUT 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 e-mail 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.

WHAT ABOUT WEBSITE 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 Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

HOW TO CONTACT MEDTRONIC

If you have questions or comments about this Privacy Statement, please contact us here.

STATE-SPECIFIC PRIVACY NOTICES

CALIFORNIA

Supplemental Privacy Notice for California Residents

This notice for California residents supplements the information contained in our Privacy Statement and applies solely to residents of the State of California. We adopt this Supplemental Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Supplemental Notice. Under the California Consumer Privacy Act (“CCPA”), you have certain rights in relation to some of your personal data, including the right to certain disclosures and explanations of rights. This section explains your rights under California law.

CALIFORNIA ‘DO NOT TRACK’ DISCLOSURES

California law (CalOPPA) requires Medtronic, plc 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.

CALIFORNIA CONSUMER PRIVACY ACT OF 2018

Categories of Personal Information We Collect

Medtronic collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“personal information”). We may have collected the following categories of personal information from consumers through our websites, apps, services, devices, or other services within the twelve (12) months preceding the effective date of this Privacy Statement:

Personal Information Category

Identifiers such as
- - Name
  - Address
  - Unique personal identifier (e.g., device ID, online identifier)
  - Internet Protocol address
  - Email address
  - Account name
  - Social security number
  - Driver’s license number, or
  - Other similar identifiers
Characteristics of protected classifications under California/federal law (e.g., age, race, sex, medical condition, etc.)
Medical information
Health insurance information
Financial information, including credit card numbers
Biometric information (e.g., imagery of the iris, retina, fingerprint, face, or other data that contain identifying information)
Commercial information (e.g., purchase history)
Internet or other electronic network activity information (e.g., browsing history, interaction with our website, etc.)
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information (e.g., call recordings)
Professional, employment-related, or other similar information

“Personal information” under the California Consumer Privacy Act does not include information that is

publicly available from government records,
de-identified or aggregated consumer information,
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, or
certain personal or financial information covered under certain sector-specific privacy laws.

For additional information, please see ‘How Does Medtronic Keep and Use Personal Information’.

Categories of Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from consumers’ interactions with us, including with our devices, applications, websites, services, and representatives
Publicly available sources
Customers, including health care providers and insurance providers
Organizations with whom we partner to provide services to consumers

Use or Disclosure of Personal Information

In the past 12 months, we have used or disclosed the personal information we collect for our operational purposes and for one or more of the following business purposes:

To provide products and services to consumers
To respond to consumer requests
To improve and personalize consumer access to and experience on our website, for example, by telling consumers about new features, products, or services that may be of interest to them
To develop records, including records of consumers’ personal information
To contact consumers with information that might be of interest to them, including information about clinical trials and about products and services of ours and of others
For analytical purposes and to research, develop, and improve programs, products, services and content
For activities to monitor and maintain the quality or safety of our products and services
For activities described to consumers when collecting their personal information or as otherwise permitted under CCPA
For U.S. healthcare providers, to link name, National Provider Identifier (NPI), state license number, and/or IP address to web pages they visit, for compliance, marketing, and sales activities
To conduct audits and perform troubleshooting activities of our websites, products, and services
To detect and protect against security incidents and deceptive, malicious, or fraudulent activity
To ensure our website, products, apps, and services function as intended, including debugging and repairing
To comply with a law or regulation, court order or other legal process

Please see ‘How does Medtronic Keep and Use Personal Information’ in our Privacy Statement for more information.

How We Share Personal Information

Medtronic will not share consumers’ personal information with an unrelated third party without permission, except as described below. Medtronic may share personal information with any member of our corporate group, including parent companies, subsidiaries, and affiliates, and other companies in which we have an ownership or economic interest for purposes that are consistent with those identified in our Privacy Statement and this Notice.

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 consumers’ personal information with a third party, we will only allow them to keep, disclose, or use consumers’ information to provide the services we asked them to provide.

We may be required to release consumers’ 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 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 consumers’ personal information in order to comply with U.S. FDA and other governmental guidance, directions, regulations, and laws.

Categories of Personal Information We Sell

We do not sell personal information of California consumers.

This does not include disclosures that are not a “sale” under the CCPA, including when

consumers instruct us to disclose their personal information,
a consumer instructs us to interact with a third party that does not sell that information,
we use or share consumers’ personal information pursuant to a written contract with a service provider that is necessary to perform a business purpose, where our contract prevents the provider from using, keeping, or disclosing consumers’ personal information for any purpose other than the reason supplied in the contract, or
consumers’ personal information is transferred as part of a transaction in which the third party assumes control of all or part of our business.

Personal Information on Minors

We do not sell personal information of California consumers, including minors.

Rights under California Law

Right to Access. If you are a California consumer, you have the right to ask us to send you the following information up to two times in a twelve-month period:
- The categories of personal data we have collected about you.
- The categories of sources from which we collected the personal data.
- Our business or commercial purpose for collecting personal data.
- The categories of third parties with whom we share personal data.
- What categories of personal data we disclose about you for business purposes.
- What categories of personal data we sell or exchange for consideration about you.
- The specific pieces of personal information we have collected about you.
Right to Delete. If you are a California consumer, you have the right to ask us to delete the personal data about you we have collected. We may deny the request if the information is necessary to:
- complete a transaction, including providing a requested or reasonably anticipated good or service, or fulfill a contract between the consumer and Medtronic;
- detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take against those responsible for such activity;
- debug to identify and repair errors impairing intended functionality;
- exercise free speech or another right provided for by law;
- comply with the California Electronic Communications Privacy Act;
- engage in research in the public interest adhering to applicable ethics and privacy laws where the consumer has provided informed consent;
- enable solely internal uses reasonably aligned with the consumer’s expectations based on the consumer’s relationship with Medtronic;
- comply with a legal obligation; or
- otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided the information.

Right to Opt-out. If a business sells personal information to third parties, California consumers have the right, at any time, to opt out of the sale or disclosure of their personal information to third parties. Medtronic does not sell personal information to third parties.

Right to non-discrimination. The CCPA grants California consumers the right not to be discriminated against for exercising your privacy rights. If you exercise your privacy rights, we will not discriminate against you, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.

Submitting a Request or Inquiry

If you are a California resident and you want to submit a request or inquiry to us regarding your California rights, you or your authorized agent can contact us here or call us at 1-866-639-6907 starting January 1, 2020. You do not have to create an account with us to submit a request.

Your request will be confirmed within ten days of receipt and we will respond within 45 days. If we need more than 45 days, we will notify you that your request is being delayed.

We can only respond to your request if it is verifiable. This means we are obligated to take reasonable steps to verify your identity or your authorized agent’s authority and your right to access the information you request. We may ask for additional information that will help us do so. We will only use that additional information in the verification process, and not for any other purpose.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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