Medtronic CareLink™ Clinician Website

Privacy Statement

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.  Medtronic values your business and has designed this statement to inform you of our information practices and policies regarding this Medtronic CareLink™ Clinician Website.  Please note that this Privacy Statement applies solely to the information we gather through this website www.medtroniccarelink.net ("Site") and does not apply to any other website operated by Medtronic or its affiliates.  We encourage you to review the privacy statements posted on other Medtronic sites when you visit them.  Both this Site and this Privacy Statement are intended for a U.S. audience.

By using this Site, you agree to the terms of this Privacy Statement.  Please read our Terms of Use and your Medtronic CareLink Network Services Agreement (the “Agreement”) to understand the general rules about your use of this Site.  Except as written in any other disclaimers, policies, terms of use, other notices on this Site, or the Agreement, this Privacy Statement and the Terms of Use are the complete agreement between you and Medtronic with respect to your use of this Site.  You may be subject to additional terms that may apply when you access particular services or materials on certain areas of this Site, or by following a link from this Site elsewhere.

INTRODUCTION

Medtronic collects and uses non-personal information differently from personal information.  Generally speaking, “personal information” refers to your name, clinic name and address, clinic telephone number, e-mail address or any other piece of information that could be used, alone or in combination with other information, to identify you – particularly in connection with your practice as a physician or other clinic employee or agent.  “Non-personal information” generally refers to information that we collect about you from your computer or your activities on the Site and cannot be linked to a specific user in any fashion.

WHAT IS NON-PERSONAL INFORMATION?

Non-personal information is information we collect through this Site that does not identify you as an individual person. It may include information such as the following:

• the type of web browser software you use (for example, Internet Explorer or Netscape Navigator)
• the name of the domain from which you access the Internet
• the Internet address of the website from which you linked directly to the Site
• the date and time you access the Site
• which pages you have visited on the Site
• personal information that has been de-identified

Medtronic may collect non-personal information from you in two ways.  First, we may collect certain information from your computer's web browser.  In addition, we may also place a text file called a cookie in the browser files of your computer when you visit.  A cookie is a numeric code that a website transfers to your hard drive for recordkeeping purposes. US Government Information Bulletin (I-034) contains a good description of cookie technology at: http://www.ciac.org/ciac/bulletins/i-034.shtml .   The information we collect using cookies is non-personal information. 

Your browser software can be set to reject cookies, including the cookies from our Site.  Please note that if you reject our cookies, you will not be able to access this Site.  We will not allow other sites or third parties to use our cookies or place cookies on this Site.

WHAT DOES MEDTRONIC DO WITH NON-PERSONAL INFORMATION?

Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information. We are always looking for ways to better serve you and improve this Site. We will use non-personal information from you to help us make this Site more useful to visitors. We also will use non-personal information for other business purposes. For example, we may use 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 "traffic statistics" and "response rates" to third parties

WHAT IS PERSONAL INFORMATION?

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

• name
• clinic name and address
• clinic telephone number
• e-mail address
• clinic role (such as physician, nurse, administrator, etc.)

In addition, from time to time, Medtronic may request that you provide us with specific information on your practice generally, your experiences with patients that use a Medtronic CareLink Monitor, and your activities on this Site.  This information is also personal information.

HOW DOES MEDTRONIC KEEP AND USE PERSONAL INFORMATION?

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

• to respond to your requests
• to personalize your access to our Site, 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 products and services of ours and of others
• for analytical purposes and to research, develop and improve programs, products, services and content
• to remove your personal identifiers (your name, e-mail address, 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 Site
• to protect our rights or property
• to protect someone's health, safety or welfare
• 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 Site 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.  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 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 visitors to the Site 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 Site
• protect our rights or property
• protect someone's health, safety or welfare
• 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 that you give us through this Site in ways that we believe are consistent with FDA and other governmental guidance, directions, regulations, and laws.

WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

If we decide to make a significant change to this Privacy Statement, we will provide a notice on the Site for a period of time after the change is made. Significant changes will also be described for you.  To date, this Privacy Statement has not been revised.

WHAT ABOUT PRIVACY ON OTHER WEBSITES?

This Site may contain links to other websites. Some of those websites may be operated by Medtronic, and some may be operated by third parties. We provide any links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others.  This Privacy Statement does not apply to any other website, even other Medtronic websites.  We are not responsible for the performance of websites 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 to provide information regarding programs, products, services and content that may be of interest to you.  In addition, this Site may allow you to communicate with us using an online form.  If your communication requests a response from us, we may send you a response via e-mail.  The e-mail response or confirmation may include your personal information, including your name, e-mail address, etc. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.

WHAT ABOUT WEBSITE SECURITY?

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.

WHAT ELSE SHOULD I KNOW ABOUT THIS PRIVACY STATEMENT?

This Site is intended for an U.S. audience.  Medtronic is located in the U.S., and our use of information that we collect on this Site is governed by U.S. law.  If you live outside of the U.S., you also understand that you are sharing your information with a company in the United States.

HOW TO CONTACT MEDTRONIC.

If you have questions or comments about this Privacy Statement, please contact us at:

            Medtronic, Inc.

            710 Medtronic Parkway NE

            Minneapolis, MN 55432-5604

            USA

            Telephone:  (763)514-4000

            FAX:  (763)514-4879

            Medtronic USA, Inc.

            (24-hour technical support for physicians and

               medical professionals)

            CareLink Toll-Free:  1-800-929-4043