Medtronic is committed to compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) as outlined in the following Statement of Privacy Principles.

This Statement of Privacy Principles describes the purposes for which Medtronic is processing your personal information, how Medtronic processes and protects personal information, and how you may access personal information that Medtronic may have about you.  Preservation of, and respect for, our customers’, business colleagues’ and vendors’, and patients’ trust is critical to our continued success.  We will always process personal information:

·         Confidentially and fairly

·         Appropriately, according to the statements we make

·         Lawfully, in accordance with applicable privacy laws, regulations and principles

Who is Medtronic?  Medtronic is the name we use to refer to our whole business, including Medtronic, Inc., a corporation based in the United States of America, 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.

When do these Privacy Principles apply?

These Privacy Principles apply when we process any personal information.  These Privacy Principles apply to data when we collect it directly from the person who the data identifies, and also when we collect data from one person (or company) that identifies another person.  Therefore, when we use the word “you”, “me”, and “I” in this Statement of Privacy Principles, we mean the individual whose personal information we are processing, whether we collect that information directly from the individual or indirectly from someone else.

This Statement of Privacy Principles does not apply when we process information:

·         about our employees in the scope of their employment relationship with us

·         where we have given other disclaimers, policies, terms of use, or other notices indicating that this Statement of Privacy Principles does not apply, or that a different policy or notice does apply that does not identify you as an individual person, including to personal information (which we define below) that we have de-identified, so that it no longer can be used to identify you.

What is data processing?

Data processing is any set of operations involving personal information, whether or not by automatic means, including collecting, using, disclosing, adapting, altering, correcting, retrieving, combining, blocking, erasing, transferring, destroying, recording, organizing, storing, and using personal information.  When we use the word “process” or “processing” in this Statement of Privacy Principles, we mean any of these types of operations.

What is personal information?

Personal information is information about an identifiable individual such as your:

·         name

·         telephone number

·         e-mail address

·         date of birth

·         address

·         social insurance number or other national identifier

·         account number

·         any other information that identifies or could identify you and relates to you

When and how does Medtronic collect personal information?

Medtronic may collect personal information in a variety of ways.  For example:

·         We may collect personal information about you in compliance with laws and regulations.

·         In some places on our web sites you have the opportunity to send us personal information about yourself.  For example, you may fill out a registration form, a survey or an e-mail form. You also may choose to allow us to personalize your visits to the web sites, in which case we will ask you for certain personal information to make your visits to our web sites more helpful to you. When this information is combined with the non-personal information that we collect through cookies, we will be able to tell that you have visited our web sites before.

·         We may collect personal information from you when you contact us for information, products, or services.

·         We may collect personal information about you in the course of engaging in commercial transactions with our customers, vendors, and other business contacts.

For what purposes does Medtronic collect and process personal information?

We may process your personal information for the following purposes:

·         to provide patients with therapy or technical support for our products or services

·         to respond to your requests and enquiries

·         to perform a contract or for contract negotiations with or about you

·         to develop records, including records of your personal information

·         to contact you by mail (or in other ways with your permission) 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, therapies, services and content

·         to remove your personal identifiers (your name, e-mail address, social insurance 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 is not subject to this Statement of Privacy Principles

·         to personalize your access to our web sites, for example, by telling you about new features that may be of interest to you

·         to enforce this Statement of Privacy Principles and otherwise protect our rights or property

·         to protect your vital interests or someone else’s health, safety or welfare

·         to comply with a law or regulation, court order or other legal obligation (for example as required by Health Canada, the U.S. Food and Drug Administration, European, and other governmental authorities to assure safe and effective use of our products and services)

·         for our other legitimate interests, unless such processing will unfairly prejudice your rights or freedoms

·         in other ways to which you consent

Will Medtronic ever use personal information to contact me with marketing messages?

We may contact you periodically in person, by e-mail, by fax, by mail, or by telephone to provide information regarding programs, products, services and content that may be of interest to you, unless you advise us that you do not wish to receive marketing or market research communications from us.  If applicable law requires that we receive your explicit consent to send you certain types of marketing communications, we will only send you those types of communications after receiving your explicit consent.

What if I no longer wish to receive marketing messages from Medtronic?

If you wish to stop receiving marketing or market research communications from us, or would like us to stop processing your personal information in any other way, you can contact us as described at the bottom of this Statement to let us know what types of communications you wish to stop receiving.  In addition, if you have received, or in the future receive, an email from us, each email we send includes an easy, automated way for you to cease receiving emails from us.

Does Medtronic ever share personal information with third parties?

Medtronic will not share your personal information with an unrelated third party without your permission, except as otherwise provided in this Statement of Privacy Principles.

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 our products.In these cases, we provide the vendor or supplier with information to process your order such as your name and mailing address. In all 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 will obligate third parties receiving personal information to comply with the privacy principles of this document.

We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition.

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 web sites 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 Statement of Privacy Principles

·         protect our rights or property

·         protect someone’s health, safety or welfare

·         comply with a law or regulation, court order or other legal process

Will Medtronic ever transfer personal information about me to countries other than the country where I am located? 

Medtronic may transfer information out of the province or country in which it was collected.  However, Medtronic will only transfer such information in the following cases:

the transfer is necessary for the performance of a contract between you and Medtronic or for pre-contractual measures taken in response to your request; or

if you consent to the transfer; or

if the data will be adequately protected in the other province or country, by contract or other protection

Medtronic has arrangements with all of its offices and affiliates that assure that personal information transferred among Medtronic companies is adequately protected, including transfers of personal information (which may include sensitive information) to Medtronic companies in the United States of America.

Other privacy legislation and changes to this Statement of Privacy Principles

Currently, there are a number of provincial privacy laws which may apply to information held by Medtronic, in addition to PIPEDA. Other provinces may enact legislation in the near future. Medtronic is committed to meeting the highest standards of information privacy required by these provincial statutes, codes and policies. As a result of legislative changes, or for other reasons, Medtronic may need to make significant changes to this Statement of Privacy Principles. If such a change is made, Medtronic will post a notice on the homepage of our web sites for a period of time after the change is made. We will also describe any major changes in this section of the Statement.

What about the security of personal information?

Medtronic takes full responsibility for the management and confidentiality of the personal information under its control, whether this personal information is held within the Medtronic organization or transferred to a third party for processing.  Medtronic has appointed a Privacy Officer that is accountable for Medtronic’s compliance with PIPEDA and other applicable privacy legislation.  We use reasonable physical, administrative, and technical safeguards to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  We also restrict access to your personal information to those employees and contractors who need to know that information to do their jobs.  You should keep in mind that no Internet transmission is ever 100% secure or error-free.  In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

How long will Medtronic maintain my personal information? 

We will not keep information for any longer than is required.  In many cases, personal information must be kept for considerable periods of time in order to make it available as and when questions or disputes arise.  Retention periods will be determined for each personal information that is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity.  We will continue to treat your personal information in accordance with this Statement of Privacy Principles so long as we retain it.

Are there any additional privacy principles relating to Medtronic web sites?

Links.  Our web sites 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 Statement of Privacy Principles does not apply to any other web sites, 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 our web sites we recommend that you review each web site’s privacy practices and make your own conclusions regarding the adequacy of these practices.

Cookies.  Medtronic may use cookies on its web sites.  Cookies are text files we place in the browser files of your computer when you visit.  The cookies may be stored on your computer’s hard drive.  The information that we collect using cookies is non-personal information.  You are always free to decline our cookies if your browser permits, but some parts of our web sites may not work properly for you if you do so.  We will not allow third parties to place cookies on our web sites.

How to contact Medtronic.

We strive to keep our records of your information accurate.  If you want access to your personal information that Medtronic maintains, notice that your information is not complete, accurate or current, or if you have questions or comments about this Statement of Privacy Principles, please contact us:

c/o Privacy Officer

Medtronic of Canada Ltd.

6733 Kitimat Road, Mississauga, Ontario  L5N 1W3

Telephone #(905) 826-6020 or 1-800-268-5346

Fax #(905) 826-6620