Statement of Privacy Principles for Europe, Middle East and Africa

In this Statement of Privacy Principles, we describe how Vitatron processes personal information. Preservation of, and respect for, our customers', business colleagues and vendors', and patients' trust is critical to our continued success. We are committed to ensuring that all your personal information that is collected is kept private and protected:

Who is Vitatron? Vitatron is the name we use to refer to our whole business, including Vitatron Holding BV and any of the companies that it controls, such as its subsidiaries and affiliates. Since 1986, Vitatron has been part of Medtronic Inc, a world leader in medical technology. Vitatron is a subsidiary of Medtronic, Inc. and offers a unique technology stream that is complementary to Medtronic's products.

When we use the words "we" or "our", we mean Vitatron.

Privacy Compliance

Our Privacy policy is compliant with the European Union Data Protection Directive (hereinafter “Directive 95/46/EC”).

When do these Privacy Principles apply?

These Privacy Principles apply when we collect and process personal information. directly from the person who the data identifies, or indirectly from someone else (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:

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.

We will always process personal information:

What is personal information?

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

Any other information that identifies or could identify you and relates to you. Some types of personal information are sensitive information. Sensitive information is defined below. In this Statement of Privacy Principles, when we use the phrase personal information, we include sensitive information unless we specifically state otherwise.

When and how does Vitatron collect personal information?

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

How does Vitatron process personal information?

We may process your personal information (other than sensitive information):

What is sensitive information?

Sensitive information is personal information revealing or relating to your health (such as your device serial number, or the date of an implant), your racial or ethnic origin, religious or philosophical beliefs, sex life, political affiliation, or trade union membership.

Will Vitatron collect or process sensitive information any differently than other personal information?

Vitatron will only collect and process your sensitive information:

For example:

Will Vitatron 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 before we send you certain types of marketing communications, we will only send you those types of communications after receiving your explicit consent.

Does Vitatron ever share personal information with third parties?

Vitatron 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 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:

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

Vitatron may transfer information out of the country in which it was collected to any country or territory in the European Economic Area and to any other country that is recognized by the European Union as having adequate privacy protections. We will transfer information to other areas only if:

Vitatron is a subsidiary of Medtronic, Inc. Medtronic, Inc. 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.

What happens if the Statement of Privacy Principles changes?

If we decide to make a significant change to this Statement of Privacy Principles, we will describe any major changes in this section of the Statement. You can always find the most current copy of this Statement and its history on the web site for your country, or contact us at the address below.

What about the security of personal information?

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 Vitatron 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 Vitatron web sites?

Links. Our web sites may contain links to web sites operated by other 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. We are not responsible for the performance of web sites operated by third parties or for your business dealings with them.

Our web sites also may contain links to other web sites operated by Medtronic, Inc., our parent company. This Statement of Privacy Principles applies only to web sites for Medtronic companies located in Europe, the Middle East, and Africa, and there may be slight variations in the Statement as posted in specific countries in Europe, the Middle East, and Africa. Therefore, whenever you follow a link from this web site to another web site, even to another site operated by Medtronic, we recommend that you review that web site's privacy 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.

Your data protection rights

According to the Directive 95/46/EC), you have the right:

How to contact Vitatron.

We strive to keep our records of your information accurate. If you ever 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 at:

Vitatron Holding B.V.
Endepolsdomein 5
6229 GW Maastricht
The Netherlands
+31 (0) 43-356 6551