Privacy Statement

Medtronic is committed to maintaining your trust by protecting Personal Information. We are committed to ensuring that your privacy is respected, and that Personal Information is handled in a transparent and lawful way. Any Personal Information you provide will only be used in accordance with this Privacy Notice. We encourage you to read this Privacy Notice carefully.

This Privacy Statement tells you how we protect and use information that we process through the Medtronic ScreenLink Application or Website (the “Application”).

This Privacy Statement was last revised on September 24th, 2018. We may change the Privacy Statement at any time and for any reason, but if we do so, we will inform you of the new contents.

Please also read the Terms of Use for the Application to understand the general rules about your use of the Application. This Privacy Statement and the Terms of Use are the complete agreement between Medtronic and the you with respect to its use of the Application.

INTRODUCTION

The Application is owned by Medtronic International Trading Sàrl based in Switzerland (“Medtronic”) and is licensed to you for purposes of helping to identify patients who are potentially indicated for a Cardiac Resynchronization Therapy, Pacemaker, Implantable Cardioverter Defibrillator, Insertable Loop Recorder and Atrial Fibrillation procedures according to the latest scientific guidelines. When we use the words "we" or "our", we mean Medtronic. When we use the word “you” or “your” we mean you as the HCP using the ScreenLink Application.

The ScreenLink Application is intended for use by HCP only. We are collecting your personal information to ensure only HCP are registering to the ScreenLink Application as intended.

The ScreenLink Application displays minimal educational content on Heart Failure, Fast Arrythmias, Bradycardia, Atrial Fibrillation, Syncope as well a calculator.

No Patient data are stored on the ScreenLink Application.

The calculator displays a few questions and completion of the questionnaire produces a recommendation for the appropriate therapy as per the latest scientific guidelines.

The information in the Application was developed with reference to the ESC, NICE, AHA and ACPG Guidelines for the prevention, detection and management of chronic heart failure, post-MI, SCA/VF/VT, bradycardia, atrial fibrillation and unexplained syncope and with reference to the position papers of European Heart Journal several Cardiovascular Journals on Cardiac Resynchronization Therapy , Pacemaker, Implantable Cardioverter Defibrillator, Insertable Loop Recorder and Atrial Fibrillation procedures.

In addition, different national guidelines may be issued by other national bodies or regulatory authorities on the subject.

Users are therefore advised to rely on Guidelines as applicable to their geography / country and on the Information for Use of the relevant implants and instruments which are components of the Cardiac Resynchronization Therapy, Pacemaker, Implantable Cardioverter Defibrillator, Insertable Loop Recorder and Atrial Fibrillation procedures.

The information in the ScreenLink Application must not be considered as an exclusive diagnostic tool for the purpose of ascertaining the right therapy indications. The final decision about the appropriate therapy indication must be based on clinical evidence, applicable clinical and professional practice protocol and not solely on the basis of the ScreenLink Application.

The ScreenLink Application is an open registration platform for physicians who are solely responsible for the accuracy of their respective healthcare professional information. Medtronic does not verify the existence and identities of those healthcare professionals registering on the ScreenLink Application.

The System collects and processes some of your Personal Information Please see below for a definition of personal and non-Personal Information, and how the System processes them.

Medtronic is the data controller. The lawful basis for processing your personal information is consent.

We may run statistics regarding the number of users of the ScreenLink Application and where they are from, but we will not contact you to provide information regarding our programs, products or services.

WHAT IS PERSONAL INFORMATION?

Personal Information is information that is processed through the App that can specifically identify you. Examples of Personal Information include:

  • First name
  • Last name
  • Hospital/clinic name
  • Post code & City
  • Country
  • Email
  • Profession
  • Specialty

HOW DOES MEDTRONIC COLLECT AND PROCESS PERSONAL INFORMATION?

We collect personal information about our users in two ways:

  1. when you directly provide information to us, e.g. by entering personal information on certain pages of the app/website.
  2. using automated means, specifically through cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website. For more information about cookies, please click here.

SECURITY

We are committed to protect the security and confidentiality of Personal Information. To prevent accidental or unlawful destruction, loss, alteration, unauthorized access or disclosure of, the Personal Information, we use appropriate technical and organizational measures to safeguard and secure the “Personal Information” we process.

We will inform you and/or the relevant supervisory authorities without undue delay should an unauthorized disclosure of the Personal Information require such a notification.

WILL MEDTRONIC SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

Medtronic will not share your personal information collected from this website with a third-party except as described in this Privacy Statement.

In the ordinary course of business, we may share some personal information with Medtronic affiliates or third-party companies that we hire to perform services or functions on our behalf.

In particular:

We use a third-party provider to administer and update our website. Your personal information will be stored on their secure server based in Europe (Germany & Ireland). For more information on the circumstances in which we may transfer your information to other countries, please see the relevant section below.

In all cases we will not share more information than is necessary, and we will not authorize any third parties to keep, disclose or use your information except to provide the requested services in line with the purposes set out above.

Please note that subject to applicable laws, we may disclose your personal information if we believe we are required to do so to comply with any law, regulation, court order, legal or government request. In the unlikely event that all or part of our business is acquired by a third party, your information may be transferred to the new corporate owner insofar as relevant to the business in question and subject to appropriate safeguards being in place.

WHAT DOES MEDTRONIC DO WITH NON-PERSONAL INFORMATION?

Non-Personal Information will be collected and processed for the same purpose as personal data and in the same context. No non-Personal Information will be stored nor shared with anyone.

YOUR PERSONAL RIGHTS AND HOW TO CONTACT MEDTRONIC

At any time, you may exercise your right to access, rectify and, as the case may be, erase, any personal information relating to you, or restrict the processing of your personal information, in compliance with applicable laws.

We will keep your Personal Information until you delete your account.

You have the right to lodge a complaint with your data protection authority.

If you have questions or comments about this Privacy Statement, or would like to exercise your rights, please contact us or the Medtronic Data Protection Officer at: rs.privacyeurope@medtronic.com.

DEFINITIONS

By “Personal Information” we mean any information which relates to an identified/identifiable natural person, in other words, any information which can lead to knowing who you are (either directly or indirectly) also called “Personal Data” or “Personally Identifiable Information”.

By “Processing” we mean any operation performed on Personal Information, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restrictions, erasure or destruction.

By “Lawful Basis” we mean the legal grounds on which Personal Information is processed. These include: Consent, Performance of Contract, Legal Obligation, Legitimate Interest, Vital Interest & Public Interest.