Privacy Policy

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.

COMPANION PRIVACY STATEMENT

INTRODUCTION

Privacy is very important to us. We also understand that privacy is very important to you. This Privacy Statement tells you how Companion Medical and our affiliates, including Medtronic MiniMed, Inc. and MiniMed Distribution Corp. (“Companion” or “we”) protect and use information that we gather through this Companion website (the “website”) as well as our InPen medical product and the software or mobile application (the “application”) that support it (“InPen Services,” and, together with the website, our “Services”). This Privacy Statement does not apply to Companion websites that do not expressly link to it. You should review the privacy statement posted on other Companion websites when you visit them. This website, the application and this Privacy Statement are intended for a U.S. audience.

By using the Services, you agree to the terms of the most recent version of this Privacy Statement. Please also read our Terms of Use to understand the general rules about your use of our Services. Except as written in any other disclaimers, policies, terms of use, or other notices on this website or application, this Privacy Statement and the Terms of Use are the complete agreement between you and Companion with respect to your use of the Services.

When we use the term “Personal Information” in this Privacy Statement, we mean information relating to an identified or identifiable individual.

WHAT PERSONAL INFORMATION DO WE COLLECT?

Information We Collect on Our Website

When you visit our website or contact us through a method provided on our website, you may provide us with personal information, including your name, birth date, address and other contact information, your doctor’s name, and pharmacy benefits information  We use this information to contact you, respond to your questions, and to provide our Services.  In some places on this website you have the opportunity to send us personal information about yourself, to elect to receive particular information, or to participate in an activity. For example, you may fill out a registration form, a survey, or an e-mail form and you may elect to receive educational material about our products and therapies.

You also may choose to allow us to personalize your visits to the website, in which case we will ask you for certain personal information to make your visits to our website more helpful to you. When this information is combined with the information that we collect through cookies and online information (described below), we will be able to tell that you have visited our website before and can personalize your access to our website, for example, by telling you about new features that may be of interest to you.

Information We Collect Through the InPen Services

We collect the following Personal Information through the InPen Services:

  • Demographic information, such as your name, date of birth, gender, height, weight and photo/avatar
  • Contact information, such as your e-mail address, phone number and mailing address
  • Information about your diabetes care, such as your diabetes type, year of diagnosis, glucose values, insulin temperature, carbs/meals and insulin type, doses, prior insulin delivery method, therapy settings and recommendations
  • Information about your use of the InPen Services and mobile device, such as app usage data and date of first use
  • Information related to your use of any linked products or services, such as a continuous glucose monitor
  • Information about your health care provider, such as your health care provider’s name and contact information
  • Information about your health insurance, such as the name and contact information for your health insurance and pharmacy benefit manager
 

HOW DOES COMPANION KEEP AND USE PERSONAL INFORMATION?

We may keep and use personal information we collect from you through our Services to provide you with access to our website and application, to facilitate the creation of your account and to otherwise provide you with, and support your use of, the InPen Services. In addition, we may keep and use your personal information:

  • to respond to your requests
  • to contact you regarding your use of the InPen Services
  • to personalize your access to our website or application, 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, to the extent permitted by law, information about clinical trials and educational and marketing communications about products and services of ours and of others
  • for analytical purposes and to research, develop and improve programs, products, services and content
  • for U.S. healthcare providers, to link your name, National Provider Identifier (NPI), state license number, and/or your IP address to web pages you visit, for compliance, marketing, and sales activities
  • to remove your personal identifiers (your name, e-mail address, social security 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 we may treat it like other non-personal information
  • to enforce this Privacy Statement and other rules about your use of this website
  • to protect someone’s health, safety or welfare
  • to protect our rights or property
  • to comply with a law or regulation, court order or other legal process
 

DOES COMPANION EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

Companion will not share your personal information collected through the Services with an unrelated third party without your permission, except as otherwise provided in this Privacy Statement.

We may disclose personal information collected through the InPen Services to health care providers, family members or other individuals involved in your care or support that you choose to register using the InPen Services to receive such information.  We may also share personal information collected through the InPen Services with partners as permitted by applicable law and subject to safeguards, and with other persons, apps and devices that you choose to link to the InPen Services. 

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 you products that you order on our website. In these cases, we provide the vendor with information to process your order such as your name and mailing address. In cases in which we share your personal information with a third-party vendor, 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 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 website 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 Privacy Statement and the other rules about your use of this website
  • protect our rights or property
  • protect someone’s health, safety or welfare
  • fulfill obligations relating to a corporate sale, merger, dissolution, or acquisition
  • comply with a law or regulation, court order or other legal process
 

COLLECTING ONLINE INFORMATION

If you visit our website to read or download information, such as information about a health condition or about one of our products, or if you use our application or other software as part of the InPen Services, we may collect certain information about you from your computer or mobile device. This information may include:

  • The name of the domain from which you access the Internet
  • The Internet Protocol address (“IP Address”) of the device you are using
  • The type of browser and operating system you are using
  • The date and time you access our website or application
  • The internet address of the site from which you linked directly to our website
  • Which pages you have visited on our website
  • The search terms you use
  • The links on which you click

Cookies: We also may collect this information through cookies, pixels, web beacons, and similar technologies (“cookies”) that work through placing a small file (like a text file or graphic) in your browser files when you visit. Cookies are used to collect information for business purposes, such as enabling essential website functions and improving the user experience. You are free to decline our cookies if your browser permits, but some parts of our website may not work properly for you if you do so. Companion may use third-party tracking and advertising providers to act on our behalf to track and analyze your usage of our sites. Companion may also use third-party providers to enable certain functions, such as third-party login. These companies protect that data in accordance with their privacy policies.  These third parties may collect, and share with us, as we may request, website usage information about visits to our sites, measure and research the effectiveness of our advertisements, and track page usage and paths followed during visits through our sites. Also, these third-party providers may place our Internet banner advertisements on other sites that you visit, and track use of our Internet banner advertisements and other links from our marketing partners’ sites to our sites. To the extent the information collected on Companion’s behalf by these third parties contains any personally identifiable information, we will protect it in accordance with this Privacy Statement.

Please refer to your browser Help instructions to learn more about managing cookies. And see below for an explanation of our use of cookies as well as how to opt out of our use of cookies.

CHOICES ABOUT COOKIES AND OPT-OUT OPTIONS

For more information on third-party advertising-related cookies and how to opt out of some cookies as you choose, see the descriptions and links below.

Click here to visit the Network Advertising Initiative site to set preferences and opt out of third-party targeting cookies.

WHAT DOES COMPANION DO WITH NON-PERSONAL INFORMATION?

Non-personal information is information that cannot identify you or be tied to you. We are always looking for ways to better serve you and improve our website, the InPen Services and the other services and products we offer. We will use non-personal information from you to help us make our website, the InPen Services and the other services and products we offer more useful. We also will 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
  • customize the information or services that are of interest to you
  • share it with or sell it to third parties
  • provide aggregated information on how visitors use our site, such as ‘traffic statistics’ and ‘response rates,’ to third parties
 

WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made and, in some cases, will notify you of the change via email. Any changes will become effective when we post the updated Privacy Statement on our website, and your use of the InPen Services following these changes means that you accept the updated Privacy Statement.

This Privacy Statement was last revised on October 31, 2020.

WHAT ABOUT PRIVACY ON OTHER WEBSITES?

This website may contain links to other websites. Some of those websites may be operated by Companion, 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 Privacy Policy does not apply to any other website, even the other Companion web sites. 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 COMPANION EVER COMMUNICATE DIRECTLY WITH VISITORS TO THIS WEBSITE?

We may contact you periodically by e-mail, mail, telephone or text if you agree to that contact to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this website allow you to communicate with us using an online form. If your communication requests a response from us, we will send you a response via e-mail. The e-mail response or confirmation may include your personal information, including personal information about your health, your name, address, etc.

ARE THERE SPECIAL RULES ABOUT CHILDREN’S PRIVACY?

We care about protecting the online privacy of children. We will not intentionally collect on our website any personal information (such as a child’s name or e-mail address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us.

WHAT ABOUT SECURITY?

Security is very important to us. We also understand that security is important to you. We have implemented security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. While we have implemented security measures, please keep in mind that “perfect security” does not exist on the internet or elsewhere and no transmission of information is guaranteed to be completely secure. 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.

HOW TO CONTACT COMPANION

If you have questions or comments about this Privacy Statement, please contact us here.

930M23699-011 30OCT2020 © 2020 Medtronic. All rights reserved. Medtronic, Medtronic logo and Further, Together are trademarks of Medtronic. Third party brands are trademarks of their respective owners. All other brands are trademarks of a Medtronic company.