PRIVACY STATEMENT

Date last updated: December 6, 2021

Please read this privacy statement carefully.

Privacy is very important to Medtronic LABS (“MDTLABS”). We also understand that privacy is very important to you. This Privacy Statement tells you how we protect and use information that we gather through hear with shruti website. Please note that Medtronic and some of its affiliates operate other websites. This Privacy Statement does not apply to situations where we have notified you that an alternative privacy statement applies, nor does it apply to other Medtronic websites. We encourage you to review the privacy statement posted on other Medtronic websites when you visit them.

Note: Medtronic LABS is and operates independently of Medtronic plc and its affiliates, which operate Medtronic’s business operations. Privacy statements for Medtronic plc and its affiliates can be found at https://www.medtronic.com. Hear with Shruti is a subsidiary of Medtronic LABS.

We recognize that data protection is an ongoing responsibility, so we will update this Privacy Statement in the event we undertake new processing practices or adopt new privacy policies. We encourage you to review this Privacy Statement each time you visit the website.

Please read our Terms of Use to understand the general rules about your use of this website. You may be subject to additional terms that may apply when you access particular services or materials on certain areas in this website, or by following a link from this website.

WHO ARE WE?

MDT LABS PBC India Private Limited is a registered legal entity underneath Medtronic LABS which operates in India. Medtronic LABS PBC, an entity established in the United States, is committed to protect your Personal Information and will be the data controller of your Personal Information collected and processed for the purposes described in this Privacy Statement.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

The information we receive, and how we use it, depends on what you do when visiting our website or using and/or subscribing to our services such as contacting us or schedule an appointment. We collect and use non-Personal Information (information that does not identify you personally) differently to your Personal Information.

Personal Information is information that can specifically identify you.

WHEN YOU VISIT OUR WEBSITE

When visiting our website, we only collect strictly necessary personal information from you. This may include aggregated data that enables Medtronic LABS to measure website performance.

You have the option to contact us via our ‘Talk to an Expert’ contact form or participate in an online hearing test. By visiting our website and potentially contacting us or using the test, we may collect Personal Information such as your:

  • First and last name
  • E-mail address;
  • IP (Internet Protocol) address when such address is associated with a specific user;
  • State you live in
  • City you live in
  • Phone number
  • Hearing test results
  • Other information you choose to submit via that form.

WHEN YOU CONTACT US

For the purpose of contacting us Medtronic LABS website, Medtronic LABS may process the following type of Personal Information about you:

  • Contact details, such as your email address, name and surname;
  • City you live in
  • Phone number
  • Your personal interests for potential (future) engagement with Medtronic LABS.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect Personal Information about our users in two ways:

  1. when you enter Personal Information on certain pages of the website. For example, you may join complete a contact form to talk to an expert or participated in the online hearing test
  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 see our cookie policy below.

FOR WHAT PURPOSES DOES MEDTRONIC LABS USE PERSONAL INFORMATION?

We may use the information that you have shared with us through the hear with Shruti website and relevant services (other than sensitive information, which is discussed separately below) for the following purposes:

  • To respond to your requests;
  • To provide the services or information you request;
  • To manage our relationship with you and facilitate any necessary follow up (e.g. by storing relevant information and preferences for a reasonable amount of time);

Medtronic LABS may also use your Personal Information to the extent necessary to achieve the following legitimate interests, so long as compatible with your rights and expectations of privacy:

  • For analytical purposes in order to research, develop and improve programs, products, services and content
  • To anonymize your information by removing any personal identifiers (your name, e-mail address, etc.) so that it may be used for other purposes. In this case, the anonymized information would no longer identify you and may be treated like other non-personal information. For more details please see the relevant section below.
  • To enforce this Privacy Statement and other rules about your use of this website
  • To protect our rights or property

Medtronic LABS also has legal grounds to use your Personal Information:

  • As necessary to protect someone's health, safety or welfare; and
  • In order to comply with a law or regulation, court order or other legal process

We may also process your Personal Information for the following operational purposes:

  • To track and manage compliance approvals and violations;
  • For activities to monitor and maintain the quality or safety of our products and services
  • To conduct audits and perform troubleshooting activities of our websites, products, and services
  • To detect and protect against security incidents and deceptive, malicious, or fraudulent activity
  • To ensure our website, products, apps, and services function as intended, including debugging and repairing
  • To comply with a law or regulation, court order or other legal process
  • Comply with laws including those regarding transparency, data subject requests and the management of training on the safe and effective use of our products
  • In the event of a legal claim: for the establishment, exercise or defense of a legal claim.

WHAT IS SENSITIVE INFORMATION?

Some types of Personal Information are 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), genetic or biometric data, your racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, political opinions or trade union membership.

This website allows the ability to process health information when you participate in the online hearing test.

WILL MEDTRONIC LABS TREAT SENSITIVE INFORMATION DIFFERENTLY TO OTHER PERSONAL INFORMATION?

Medtronic LABS will only collect and process your sensitive information:

  • In case you share such information i.e. through the ‘Online Hearing Test’ contact form you have given your explicit consent
  • To protect the vital interests of you or another person, in cases where your explicit consent cannot be given or reasonably requested
  • According to applicable laws which include suitable and specific measures to safeguard your fundamental rights and interests
  • To establish, exercise, or defend a legal claim

For example:

  • We may collect sensitive information directly from you, when you voluntarily provide it to us for a particular purpose (e.g. when you contact us or participate in the online hearing test.

NON-PERSONAL INFORMATION

Non-personal information is information that cannot identify you or be tied to you in any way. Therefore, the non-personal information that we collect through this website does not identify you as an individual person and will not be linked to you. It may include information such as the following:

  • The type of web browser software you use (for example, Internet Explorer)
  • The name of the domain from which you access the Internet
  • The Internet address of the website from which you linked directly to our website
  • The date and time you access our website
  • Which pages you have visited on our website
  • The geographic location of the server you use to access our website
  • The links on which you click
  • Personal Information that has been made non-personal or anonymized (i.e., information that no longer reflects or references an individually identifiable user)

If you visit our website to read or download information, such as information about the Shruti program, we may collect certain non-personal information about you from your computer. This information is collected from your computer's web browser.

If you only read or download information on our website, we will only collect your Internet Protocol (IP) address. We do not collect or learn your name, e-mail address, home address, or other Personal Information about you.

For more information about how we use cookies to collect information about visitors to our website, please see our cookie policy below.

WHAT DOES MEDTRONIC LABS DO WITH NON-PERSONAL INFORMATION?

We are always looking for ways to better serve you and improve our products, services and website experience. We will use non-personal information from you to make this website more useful to visitors. We may also use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:

  • Create reports for internal use to develop programs, products, services or content
  • Adapt or improve the information or services provided
  • Share with third parties not acting under contract for Medtronic LABS (i.e. social media companies)
  • Provide information on how our site is used, such as "traffic statistics" and "response rates" to third parties

DIRECT MARKETING AND EDUCATIONAL MATERIALS

Medtronic LABS may wish to provide you with educational materials or other information about our products and services, as well as information about clinical trials or the products and services of others that might be of interest to you, based on the information you have shared with us and that we have collected through cookies or similar techniques regarding your use of Medtronic LABS websites. For more information on how we use cookies, and your choices in that regard, please see our Cookie policy below.

We will ask you to "opt-in" or affirmatively consent to the use of your Personal Information for the purposes of such communications, or our legitimate interest in accordance with applicable laws.

If at any time you decide not to receive any educational, commercial or promotional information related to our products and services or regarding the products or services of our affiliates or service providers, you can unsubscribe by clicking on the unsubscribe button available in our email communication with you.

Please note that if you opt not to receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any account you may have with us, to respond to your requests, to execute agreements with you, or to provide you with information that Medtronic LABS is required by law to provide, e.g. regarding product recalls.

SURVEYS

From time to time we may invite you to participate in a survey to determine satisfaction levels, identify areas of potential improvement or to carry out market research. We may send you a specific invite to participate in such a survey on the basis of our legitimate interests in conducting the survey, or on the basis of your prior “opt-in” consent to receive such communications, in accordance with applicable laws. You may opt-out of receiving any such future communications in the manner detailed in the section above.

The Personal Information that is collected for the purpose of the survey may include your email address, phone number, survey results, and any free-text message you may have written in the survey.

We process your Personal Information as part of the survey for carefully considered and specific business purposes which are in our legitimate interests and which we believe also often benefit you, based on our assessment that our legitimate interests do not override your freedom and data protection rights.

The business purpose of collecting your data is to reply to survey feedback you may have provided, specifically:

  • Should you have indicated an issue which we need to take action to resolve
  • In order to gain further insight to the experience you have described
  • To inform you of any action we might take internally to resolve your issue or enhance your experience

DOES MEDTRONIC LABS EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

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

We may share Personal Information with any member of our corporate group, including parent companies, subsidiaries, and affiliates, and other companies in which we have an ownership or economic interest for purposes that are consistent with those identified in our Privacy Statement and this Notice. In the ordinary course of business, we will share some Personal Information with companies, such as service providers, that we hire to perform services or functions on our behalf.

For example, we may:

  • Use a third-party application or platform to allow us to manage and keep track of our communications with you.
  • Use our company affiliates to provide services relating to your Personal Information e.g. we may store your information on a secure server based at our affiliate’s site in India. 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 addition, we may use and disclose your Personal Information to third parties if necessary to:

  • enforce this Privacy Statement and the other rules about your use of this website
  • protect our rights or property
  • protect someone's health, safety or welfare
  • comply with a law or regulation, court order or other legal process
  • investigate or take action in cases of suspected fraud or illegal activities

DO WE TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?

In certain cases, Medtronic LABS may transmit Personal Information collected on this website to our affiliates or third party service providers in other countries, but only in furtherance of the purposes set out in this Privacy Statement and to continue the uptime of the website. i.e. when the data center in India gets damaged beyond use. More details can be requested by contacting us here.

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?

We will only keep your Personal Information for so long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this Privacy Statement. For example, in case you participate in a program via our website, we will delete the Personal Information provided as part of that program within a reasonable time after its completion (e.g. thirty (30) days after completion will normally be considered reasonable unless we have lawful grounds to retain some of the information for longer (e.g. if necessary for validation or to comply with recordkeeping obligations)).

ARE THERE SPECIAL RULES ABOUT CHILDREN'S PRIVACY?

We care about protecting the online privacy of children. We will not intentionally collect any Personal Information (such as a child's name or e-mail address) from children under the age of 16 without the consent of someone holding parental responsibility. If you think that we have otherwise collected Personal Information from someone under the age of 18 please Contact Us.

WHAT ABOUT WEBSITE SECURITY?

Security is very important to us. We also understand that security is important to you. We use industry standard measures to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no website or email transmission is 100% secure and we encourage you to therefore take special care in deciding what information you send or request via email, and take appropriate precautions such as keeping any health information, usernames and passwords you use confidential.

YOUR RIGHTS

Subject to applicable law, you are entitled to access, to request rectification, deletion or restriction of the processing of your Personal Information, to object, based on your particular situation, to any use or Processing of your Personal Information which we have based on our legitimate interests, as well as to request your Personal Information in a structured, commonly used and machine-readable format (data portability), to the extent possible in relation to the purpose and applicable law.

Please note that the above rights are generally applicable to individuals in India but may be limited in some other jurisdictions according to applicable law. To exercise any of these rights, please contact us at privacyandsecurity@mdtlabs.com. Please note that in accordance with applicable laws, we may ask you to provide some proof of identity before we can process your request. If we have based our collection or use of your Personal Information on your consent then you also have the right to withdraw your consent at any time in the same way as it was given, or by sending a request in the above manner.

HOW TO CONTACT MEDTRONIC LABS

If you have questions or comments about this Privacy Statement, please Contact Us.

COOKIE POLICY

INTRODUCTION

This Cookie Policy provides information on how cookies and similar technologies are used on this hear with Shruti website and associated mobile sites, applications (“apps”), or widgets that link to this Cookie Policy, so that you can make an informed choice about your acceptance of cookies.

WHAT ARE COOKIES?

A “cookie” is a small text file that is placed and stored on your computer, smartphone or other device or internet browser by websites or apps that you visit. Cookies allow small amounts of information about your device to be passed to our web server. They allow websites to recognize your computer, smartphone, tablet or other device as your browse. Web beacons, pixels, JavaScript, and other tracking technologies also utilize cookies and or use invisible images or code to gather information about a visitor session in a manner similar to cookies. Depending on how long a cookie remains in place we can describe cookies as either session cookies or persistent cookies:

SESSION COOKIES

A session cookie is deleted when you close the relevant website. A session cookie may allow a website to remember you while you are browsing the site, but the cookie will be removed when you log out or close the webpage or your internet browser. For example, a session cookie may be used to allow features such as shopping carts to remember if you have added an item to your cart while you browse for other items you wish to purchase on the website.

PERSISTENT COOKIES

A persistent cookie remembers you for a particular period of time. It remains stored on your device or internet browser for that time (it could be minutes, days, months or years) after you have logged out or closed your browser. For example, persistent cookies may be used to remember if you have selected certain preferences on a website (e.g. your language selection).

HOW DOES MEDTRONIC LABS USE COOKIES?

hear with Shruti uses both session and persistent cookies. Cookies and other similar technologies are used by hear with Shruti for several different reasons. Cookies are sometimes necessary for our website to operate correctly and enable functionality such as secure logins to work properly. Cookies allow us to count the visitors to our website and learn how they use our website and its features, enabling us to continually improve the experience. Cookies may also allow us to tailor the content of a website to your preferences. For details on the cookies used on this website by Medtronic LABS, please see below.

COOKIES WE USE

The cookies that may be used on this website by Medtronic LABS can be categorized as follows:

STRICTLY NECESSARY OR ESSENTIAL COOKIES

These cookies are needed to ensure that this website operates correctly and securely, enabling you to move around the website, use its features, and record your preference regarding our use of cookies on your device. Without these cookies, certain functionality (such as log-in to access controlled sections of the website, or to enable an online shopping cart to keep track of items for purchase) would not be available and you would be unable to make use of certain services offered by the website. These cookies do not gather information about you for marketing purposes, and they are not used to generally monitor your activity on the internet.

FUNCTIONALITY COOKIES

These cookies allow a website to remember the options you have selected i.e. the user settings in the web video player screen and any customization you have made (such as to font size) or personalization options as part of your online experience. They may also be used to provide certain services that you can make use of, such as video content or allowing comments to be left on a blog.

ANALYTICS/PERFORMANCE COOKIES

These cookies are used to manage and improve how the website works and can help us to identify issues you may have with using our online services. These cookies may be used to record visitor numbers and other web analytics metrics. These cookies are not used to target you with online advertising. Without these cookies we will have limited information on how our website is performing and will be less able to make relevant improvements to the browsing experience.

SOCIAL MEDIA CONTENT SHARING COOKIES

Our website may include integrated link that allows you to log into your social media account to share content or comments. The social sharing cookies and similar services may use cookies to identify you as a member of the social media network in question.

DETAILS OF COOKIES THAT MAY BE USED

TYPE OF COOKIE COOKIES PURPOSE
Analytic _ga
_gid
_gat_gtag		 This group of cookies is set by Hear with Shruti provide analytic and performance related data for the site. This data relates both to how the site is utilized and to how the site performs.
Functionality: PHPSESSID Hear with Shruti embeds this cookie to store information in contact form so they can later be reused on the website if you decide to fill out another form on the Hear with Shruti website.

PRIVACY AND COOKIES – YOUR PERSONAL DATA

In certain instances, the information communicated using cookies, in particular when combined with unique identifiers and other information received by servers, may be used to create individual profiles. In this manner the information collected may not be considered anonymous but could be personal data which might allow a particular individual to be identified. Medtronic LABS may combine the information we receive using cookies with that from other sources, such as on affiliated websites. In case any personal data is available to Medtronic LABS through data collected via cookies then our privacy policy, available here provides more details on the use that we may make of such personal data, and your rights in this regard.

YOUR CHOICES/HOW YOU CAN CONTROL COOKIES

You have several options for controlling how cookies are used on your device or browser. You can opt to receive a notification when cookies are set, you can delete cookies that have already been set, and you can choose to refuse all or certain cookies. For further details on the options available visit www.allaboutcookies.org or https://cookiepedia.co.uk/how-to-manage-cookies.

Please note that if you make updates to your browser or device settings or use an online link to opt out of cookies, those updates only apply to the device where you made the changes.

If you disable or block all cookies, then the relevant Medtronic LABS website will not work effectively. In addition, disabling or blocking certain cookies may mean that some features offered by Medtronic LABS may not operate as intended, or you may not have access to certain features or personalization settings.

BROWSER SETTINGS

Most browser settings allow you to adjust your settings to receive a notification when a cookie is being set or updated or can restrict or block certain types or all cookies. For more information please consult the “Help” section of your browser.

DEVICE SETTINGS

Your device settings may also allow you to prohibit mobile app platforms (such as Apple or Google) from sharing with Medtronic LABS certain information obtained by automated means.

OPTING OUT OF SPECIFIC COOKIES

You may also opt out of specific cookies directly with the provider of the cookie. For more details, please follow the links below:

SOCIAL MEDIA CONTENT SHARING

Facebook Social Plugin:
https://www.facebook.com/help/www/443483272359009
https://www.facebook.com/help/www/213802165366955

LinkedIn:
http://www.linkedin.com/legal/privacy-policy

Instagram:
https://help.instagram.com/155833707900388/%22

Twitter:
https://twitter.com/en/privacy

Pinterest:
https://policy.pinterest.com/en/privacy-policy

CONTACT US

If, at any time, you have requests or queries concerning this policy please contact us at: privacyandsecurity@mdtlabs.com

EFFECTIVE DATE AND CHANGES

This version of the cookie policy is effective as of 6th of December 2021. We may update this Privacy statement from time to time.

How Shruti Program can Help You to Get Your Self Checked?

Shruti program will connect you to an expert telecaller who will guide you to get the nearest audiologist or doctor for consultation. A doctor or an audiologist can consult you for your journey of healthy hearing.