Medtronic does not disclose your personal data (including health-related data) with third parties except as described in this privacy statement.
In the ordinary course of business, we may share your personal data (including personal health-related data) with third-party service providers to perform services on our behalf and only based on our documented instructions, including:
- Information Technology and hosting services;
- Postal services, couriers or other freight services to ship the products ordered in relation to your diabetes therapy management,
- Customer support and communication services, such as to send you marketing communication you have signed up for, as well as urgent (non-marketing) communication about Medtronic products and services,
- Consulting services regarding product and/or service development, security and technical strategy,
- Survey management solutions to manage surveys we may invite you to participate to,
- Legal and professional services to receive legal advice and manage legal disputes, where applicable.
Where our service providers need to have access to your personal data, we will (1) select providers who respect your privacy and comply with applicable data protection laws; (2) only give them access to the information they need to perform their services; (3) ensure that they will only use the information for the purposes agreed in our contract with them and protect that information in accordance with applicable data protection laws.
We may also share your personal data (including health-related data) with our Medtronic affiliates as described below.
|Medtronic MiniMed Inc. (18000 Devonshire Street, Northridge, CA 91325, United States of America)
||Legal manufacturer of Medtronic medical devices used in connection with diabetes therapy management. Medtronic MiniMed Inc. is responsible for processing your personal data as described above in connection with the following activities:
- To comply with legal requirements, such as vigilance reporting, post-market surveillance, and correspondence with competent authorities;
- To provide advanced technical assistance as requested by Medtronic local affiliate(s);
- To support its research and development activities on the Solutions by means of internal statistical reports based on aggregated data.
|Medtronic International Trading sàrl (Route du Molliau 31, 1131 Tolochenaz, Switzerland)
||Responsible for the import and distribution in Europe, Middle East and Africa (EMEA) of products manufactured by Medtronic MiniMed Inc. and for the processing of your personal data in connection with the following activities:
- To develop its research and development activities on diabetes therapy management solutions, as well as its marketing activities in the EMEA region by means of internal statistical reports based on aggregated data.
|Medtronic local affiliate in your country
||Medtronic local affiliate is responsible for the processing of your personal data in connection with the following activities:
- Local activities carried out in relation with the Solutions and services in the concerned country, including registration with local authorities, technical assistance and escalation to Medtronic MiniMed Inc. as needed;
- To comply with contractual arrangements executed with you and/or, where applicable, with local institutions which may be associated to your diabetes therapy (e.g. hospitals, health insurance companies);
- To support local marketing activities by means of internal statistical reports based on aggregated data.
|Medtronic Customer & Product Support in your country
||Processes your personal data for technical support provided on behalf of Medtronic local affiliate and escalation to Medtronic MiniMed Inc. as needed.
|Medtronic Bakken Research Centre BV (the Netherlands)
||Processes your personal data on behalf of Medtronic MiniMed Inc. and Medtronic International Trading sàrl to create statistical reports.
|Medtronic BV (the Netherlands)
||Authorized representative of Medtronic MiniMed Inc. in the European Union under the European regulation on medical devices. Medtronic B.V. processes your personal data on behalf of Medtronic MiniMed Inc. to comply with legal obligations under applicable medical device regulations, especially for post-market surveillance and vigilance reporting purposes.
Medtronic maintains appropriate technical and organizational measures designed to protect your personal data against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure, or access.
Your personal data (including health-related data) is stored on servers located in the European Economic Area (“EEA”) but we may also transfer your information to Medtronic affiliates and/or third-party service providers located outside of the EEA as described above, including in the United States of America that has not been recognized by the European Commission as providing an adequate level of data protection.
Where there is a need to transfer your personal data to Medtronic affiliates or to third-party service providers, we will ensure that there are appropriate safeguards in place to protect your personal data as required by applicable laws. When your personal data need to be transferred outside the EEA, United Kingdom or Switzerland, we will implement appropriate safeguards to ensure an adequate level of data protection, including executing data transfers agreements based on the European Commission’s Standard Contractual Clauses.
We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use the personal data you have provided to us in a manner consistent with this privacy statement. Following such sale or transfer, you may contact the entity to which we transferred your personal data with any inquiries concerning the processing of that personal information.