MEDTRONIC PRIVACY NOTICE
For TriageHFPlus
Last updated: December 2024

This Privacy Notice describes how Medtronic collects and processes information about you
(“personal data”) when using the TriageHFPlus mobile application (“Mobile App”). The Mobile App is
developed by a third-party provider named Airon Telematica Srl and is operated by Medtronic.
Medtronic is the name we use to refer to our whole business, including Medtronic plc. 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.

Medtronic provides certain services, named One Hospital Clinical Services (“OHCS”) to the medical
institution or physician that provides you with medical treatment, if you are a patient. Your medical
institution and/or healthcare professional is solely responsible for the processing of your personal
data for the provision of your medical treatment and care. As part of the OHCS services, Medtronic
is entrusted to handle personal data about you, including health data, on behalf of your medical
institution in connection with your medical treatment.
The Mobile App is made available to you to allow you to transmit your personal data to your treating
physician when you are enrolled into the OHCS service. Medtronic OHCS Service is a service
provided by Medtronic to your hospital aiming to support the care optimization of your hospital with
data collection, management, analysis, and reporting of personal, technical and health data of
patients.

Medtronic processes your personal data in connection with the activities described below, including
when you install the Mobile App on your electronic device, when you share data through the Mobile
App, or when data from your electronic device is shared with us.

You have been informed by your medical institution and/or your physician about the processing of
your personal data when you are enrolled into the OHCS services. In this context we process your
personal data on behalf, and under the instruction, of your medical institution. If you have questions
on the processing of your personal data in relation to the OHCS services and the use of the Mobile
App, please contact your medical institution or your physician.

This privacy notice does not apply when you have been notified that an alternative notice applies (for
example on other Medtronic websites). The Mobile App may contain links and/or connect to other
websites. Some of those websites may be operated by Medtronic, and some may be operated by
third parties.

This privacy notice does not apply to any other application or website, even if operated by Medtronic.
Please read the notice at each place you visit to see how that location processes your personal data.

Personal data we obtain and how we use it
This section describes how Medtronic obtains and uses your personal data collected via the Mobile
App on behalf of your medical institution. You may choose not to provide this information, but then
you may not be able to access and use the Mobile App.

Mobile App Registration, Account Creation and Access

To create your account, your physician will ask for your phone number and optionally for your email
address. The physician will generate a pin code that will be sent directly to your phone number via
text message and/or to your email address.

From this moment on, you will be able to access the Mobile App using your phone number and pin
code as credentials.

Should you lose your credentials or change your phone number, we advise you to inform your
physician. Your physician will be able to update your contact information and to generate a new pin
code as needed.

• What personal data we obtain

In order to create an account, and when using the Mobile App, the types of personal data we may
obtain or process about you include:

o Identification information, such as the user ID number generated by the Mobile App, age;
o Login credentials, such as your username/email address and pin code;
o Contact details, such as your email address and mobile phone number, which we will use to

send you a verification code;
o Health (related) data, such as your weight, height, blood pressure, heart rate, respiratory

rate, state of serenity, presence of symptoms such as tiredness, palpitations, shortness of
breath, visit to your physician and medical institution, medications, date of compilation of a
questionnaire;

o Optional data as determined by your physician, such as gender;
o Device information including device description, device model and manufacturer, version of

your operating system, unique device ID, platform, date of registration, IP address, and any
other data you choose to provide;

o Images and video, should you choose to use the Lifelight feature available on the Mobile App.

• How we use your data

We collect and use personal data shared by you when using the Mobile App for purposes determined
by your medical institution or your physician.

• To create and manage your account, including to authenticate you and ensure account
security;

• The Mobile App will allow you to transmit data to your physician, by asking you questions.
The answers provided by you in the Mobile App will automatically be transferred to and will
be visible by your medical institution/physician . The information that you will share will be
used by your physician to determine the presence of symptoms such as palpitations,
tiredness and shortness of breath and your general state of health;

• To allow you to use the Lifelight feature, where you choose to. The Lifelight feature is a
solution to estimate your pulse rate, respiratory rate, and blood pressure. It is based on
photoplethysmography (PPG), which measures the light reflected from your skin and
extracts a data signal that is analyzed with an automated algorithm that provides the
aforementioned measurements. When using this functionality, you will be asked to confirm

your age, height, and gender at birth; this information are needed to allow the algorithm to
perform the measurement.

• To determine the frequency of your use of the Mobile App, in particular to identify areas of
improvement which may contribute to the safety, security and quality of the services
rendered to your medical institution;

• To send notifications to the user, where applicable, if you have selected this option through
the settings of your mobile device.

We also collect and process device data from your mobile device in order to request permission or
access to mobile device camera, to detect and authenticate the identity of the user trying to access
the Mobile App and to send push notifications. You can opt-out or control and manage your
preferences by using your mobile device’s settings at any time.

Cookies and Similar Technologies

When you use the Mobile App, certain information may be collected by standard practices, including
cookies and similar technologies, such as authentication cookies. Authentication cookies
automatically identify your browser or your device when you log in as a registered user. They thereby
serve as identifiers that save you from having to log in repeatedly, if you request so. While personal
data collected through these technologies is not shared for money or other similar compensation,
the use of these technologies may be considered personal data sharing under applicable law. The
types of technologies, purposes of use, parties involved, and controls available to you, which may
vary across Medtronic’s digital offerings, are detailed in our Cookie Policy.

Data Sharing
In the ordinary course of business in carrying out the purposes described in this notice, we may share
your personal data with certain categories of third parties, including:

Medtronic affiliated companies given the corporate structure of Medtronic, your personal data may
be shared with other affiliates within the Medtronic group.

Service Providers: Medtronic may share personal data with relevant third-party service providers,
who act on our behalf to fulfill the activities noted in this privacy notice, including IT providers and
providers of communication tools, such as Airon Telematica srl, located in Italy which develops the
Mobile App on Medtronic’s behalf, and Xim Ltd, located in the United Kingdom, which provides the
Lifelight feature on the Mobile App.

International Transfers
In some cases, Medtronic may transmit, or store personal data collected to affiliates, providers, or
sites in other countries. We will only transfer personal data as allowed by applicable law to further the
purposes set out in this document. Where personal data is transferred to another country, we will
implement appropriate safeguards to ensure an adequate level of data protection as provided for by
applicable law. This can include selecting service providers located in a country recognized as
providing an adequate level of data protection, and implementing safeguards based on standard
data protection clauses (such as the European Commission’s Standard Contractual Clauses), where
applicable.

Data Retention
We will only keep your personal data for so long as we are instructed by your medical institution to
whom we provide the OHCS services.

Your Privacy Rights
Your Rights

You may have some of the rights below relating to your personal data, depending on applicable
laws. To the extent provided by applicable law, you can:

• request access to the personal data processed about you;
• ask to correct information about yourself you think is inaccurate or incomplete;
• object, based on your particular situation, to any use or processing of your personal
data based on your medical institution’s legitimate interests;
• withdraw the consent you previously provided to your medical institution for using
your data, where applicable;
• to receive, in a structured, commonly used and machine-readable format, the
personal data you have directly provided and to have this information transmitted to
another company, where it is technically feasible. This right may apply only in certain
circumstances, where you have provided your personal data to your medical institution
based on your consent or a contract with your medical institution to which you are party;
• to restrict or limit the use of your personal data;
• to ask to delete your personal data. Note that this right applies only when your data
is no longer necessary in light of the purposes explained in this privacy notice and there
is no legal or regulatory obligation which obliges your medical institution to keep it.

If you wish to exercise any of your rights, please contact your medical institution.

Updates to this Privacy Notice
This Privacy Notice may be updated periodically to reflect changes in how your personal data is
collected and used when you use the Mobile App in context of the OHCS services. We will indicate at
the top of the privacy notice when it was most recently updated.

End user license agreement
NOTICE TO USER: This is a legal agreement between you (an individual or entity, referred to
hereinafter as “you”) and Medtronic Italia S.p.A (“Medtronic”) for the “TriageHFPlus” mobile
application, including any related documentation, updates and upgrades (collectively referred to
hereinafter as the “Application”).

BEFORE USING THE SOFTWARE, YOU NEED TO REVIEW AND AGREE TO THE TERMS AND
CONDITIONS OF THIS END USER LICENSE AGREEMENT AND THE PIVACY STATEMENT
(“Agreement”).
If you do not agree with the terms and conditions of this Agreement, you are not authorized to use
the Application. This Agreement only apply to this Application, and do not apply to any other
applications, web sites or software operated by Medtronic or its Affiliates.
You can enter in the Application your information and any others notes you decided to enter.
The data are transmitted by you via your mobile data service or via wireless network to a server
located in European Union and Medtronic is not responsible for this connection.

1. GRANT OF LICENSE. This Application is developed by Airon Telematica S.r.l. on behalf of
Medtronic and Medtronic has all the rights to grant you and hereby grants you a limited, nonexclusive,
non-assignable and non-transferable license to use the Application in compliance with this
Agreement.

2. OTHER RIGHTS AND LIMITATIONS. You agree not to reproduce, modify, separate the
components of, adapt or translate or otherwise create derivative works from, the Application and
further agree not to attempt to reverse engineer, decompile, disassemble or otherwise attempt to
discover the source code of the Application.

You may not rent, lease, distribute or lend the Application to third parties and you shall enter only
your data (as opposed to data of third parties) into the Application. You agree not to use the
Application unlawfully or for unlawful purposes, including, without limitation, any use that violates
the privacy rights of third parties. You also agree not to damage, disable, overburden, interfere with,
or impair Medtronic services (or any network or device connected to a Medtronic service).

3. OWNERSHIP. Except as explicitly provided otherwise herein, this Agreement shall not alter
or modify title, ownership rights, and intellectual property rights in and to the Application. There is
no transfer to you of any title to or ownership of the Application and this Agreement shall not be
construed as a sale of any rights in the Application.

You agree not to remove or alter any copyright, trademark, registered mark, or other proprietary
notices on any copies of the Application. Medtronic and Airon Telematica S.r.l. reserve all rights not
expressly granted herein.

4. NO MEDICAL SERVICES AND NO DATA ACCURACY. You acknowledge that Medtronic
does not provide any licensed health care service, nor does Medtronic provide any medical, health,
or other professional service, advice, or decision-making through this Application. Medtronic also
does not monitor and verify the accuracy of the data you enter in the Application.

5. UPGRADES. If you acquire an upgrade, updated version, modified version, or additions from
Medtronic to or for this Application, the upgrade, updated version, modified version, or addition,
shall be included in the term “Application” and governed under this Agreement.

6. LIMITED WARRANTY AND REMEDY. Medtronic warrants to you that the Application will
perform substantially in accordance with the Application user documentation. Medtronic does not
warrant that the operation of the Application will be uninterrupted or error free or that the functions
of the Application will meet your needs or requirements. This Limited Warranty is void if failure of
the Application resulted from accident, abuse, or misapplication. You are solely responsible for
decisions made and actions taken based on your use of the Application.

THE STATED LIMITED WARRANTIES AND REMEDY ARE EXCLUSIVE AND IN LIEU OF ALL OTHERS.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW MEDTRONIC DISCLAIMS ALL
OTHER WARRANTIES, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION, ALL
WARRANTIES OF NON-INFRINGEMENT, INTEROPERABILITY WITH ANY PARTICULAR DEVICE,
MERCHANTABILITY, AND FITNESS FOR A PARTICULAR PURPOSE. SOME JURISDICTIONS,
HOWEVER, DO NOT ALLOW EXCLUSIONS OR LIMITATIONS OF IMPLIED WARRANTIES, AND IN
SUCH JURISDICTIONS, THE ABOVE LIMITATION MAY NOT APPLY TO YOU.

7. LIMITATION OF LIABILITY. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW,
IN NO EVENT WILL MEDTRONIC OR ITS SUPPLIERS BE LIABLE FOR ANY DAMAGES, WHATSOEVER,
WHETHER DIRECT, INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES,
WHETHER ARISING UNDER CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY,
BREACH OF WARRANTY, MISREPRESENTATION, OR OTHERWISE, INCLUDING WITHOUT
LIMITATION, DAMAGES FOR LOSS OF, INTERRUPTION, LOSS OF INFORMATION, PERSONAL
INFORMATION OR OTHER LOSS, ARISING OUT OF THE USE OF OR INABILITY TO USE THE
APPLICATION, OR ARISING OUT OF THIS AGREEMENT, EVEN IF MEDTRONIC OR ITS
REPRESENTATIVE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

THE PREVIOUS LIMITATIONS WILL NOT APPLY IN THE EVENT OF MEDTRONIC’S INTENT OR
GROSS NEGLICENCE

8. INDEMNIFICATION. NO ENDORSMENT. By your use of this Application you agree to defend,
indemnify and hold Medtronic, its officers, directors, employees, agents, parent, and partners,
harmless from and against any claims, actions or demands, liabilities and settlements including
without limitation, reasonable legal and accounting fees, resulting from, or alleged to result from,
your use of this Application, including all content and services in a manner that violates or is alleged
to violate this Agreement. Medtronic shall provide notice to you promptly of any such claim, suit, or
proceeding and shall reasonably cooperate with you, at your expense, in your defense of any such
claim, suit or proceeding. Medtronic does not recommend or endorse any opinions, specific tests,
products, or procedures that may be mentioned in this Application. Medtronic assumes no liability
or responsibility for damage or injury to persons or property arising from any use of any product,
information, idea, or instruction contained in the materials provided to you.

9. EXPORT RESTRICTION. You agree that the Application will not be shipped, transferred or
exported into any country or used in any manner prohibited by any other restrictions, law or
regulations.

10. OTHER RESTRICTIONS. Misusing a Medtronic product or software, improperly accessing
information that a Medtronic product transmits, use of the Application on a “jailbroken” and/or any
other unauthorized actions may place you at risk, cause any Medtronic product or the Application to
malfunction, is not permitted and voids any applicable warranty. The Application made available by
Medtronic to you may be interrupted or unavailable.

11. GOVERNING LAW AND GENERAL PROVISIONS. This Agreement shall be governed and
construed under the applicable local law. This Agreement is the entire agreement between the
parties related to the Application. This Agreement shall be binding upon, and inure to the benefit of,
the parties hereto and their respective successors, assigns and legal representatives.

If any provision herein is found void or unenforceable, it will not affect the validity of the balance of
the Agreement, which shall remain valid and enforceable according to its terms. This Agreement
may only be modified in writing signed by both Parties.

12. AGREEMENTS UPDATE. This Agreement was last reviewed and amended in September
2024. Medtronic may change this Agreement at any time and offer to you the opportunity to review
the updated Agreement and accept the modified terms. Continued use of this Application means
that you accept the most recent version of the Agreement.

13. CAPACITY AND AUTHORITY TO CONTRACT. You represent that you are of the legal age
of majority in your state of residence or have your legal guardian accept on your behalf the terms of
this Agreement.

14. CONTACT INFORMATION. In case of questions or doubts about the Application or this
Agreement, including any requests for access to data, corrections, restrictions or any changes to
any applicable consent, you can contact us writing to privacyeurope@medtronic.com.

15. PRIVACY STATEMENT. Medtronic is committed to protecting your privacy. Personal data
may be collected and processed depending of your use of the Application. Please read the following
Privacy Policy to learn how we protect and use information that we gather through this Application.

16. OPEN SOURCE SOFTWARE LICENSE NOTICE. This clause identifies the Open Source
Software that may be separately called, executed, linked, affiliated, or otherwise utilized by this
Application. Such Open Source Software is licensed to users subject to the terms and conditions of
the separate software license agreement for such Open Source Software. Use of the Open Source
Software by you shall be governed entirely by the terms and conditions of such license. The
source/object code and applicable license for any Open Source Software can be obtained at the
following site(s):

Apache Cordova – https://cordova.apache.org/

Licensed under the Apache License, Version 2.0 (the "Apache License"). You may not use this file
except in compliance with the Apache License. You may obtain a copy of the Apache License at

http://www.apache.org/licenses/LICENSE-2.0

Unless required by applicable law or agreed to in writing, software distributed under the Apache
License is distributed on an "AS IS" BASIS, WITHOUT WARRANTIES OR CONDITIONS OF ANY
KIND, either express or implied. See the Apache License for the specific language governing
permissions and limitations under the Apache License.