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Global Privacy Policy
Revised June 16, 2015
Introduction
St. Jude Medical, Inc., and its affiliates (together referred to in this policy
as St. Jude Medical, we and/or us) are committed to protecting and respecting the priv
acy of individuals. We collect, use, disclose, and otherwise process personal in
formation in accordance with applicable privacy/data protection laws in force in
the jurisdictions in which we operate.
This policy sets out how and why we collect, use, and disclose personal informat
ion, whether in oral, electronic, or written form, of individuals who interact w
ith St. Jude Medical. It also explains how we safeguard the information you prov
ide to us directly or indirectly.
This privacy policy also covers the www.sjm.com family of Web sites, available t
o visitors located throughout the world, and operated for different purposes. Th
ese Web sites are operated in the United States in accordance with laws of the U
nited States, and visitors to our Web sites should be aware that the laws of the
United States may differ from those of your country of residence. Where we oper
ate country-specific Web sites, those Web sites are operated in accordance with
the laws of that specific country.
St. Jude Medical reserves the right to change this privacy policy at any time. W
e will post changes on this Web site, which will take effect once posted.
What Is Personal Information?
Personal information means information that identifies you individually, such as
your name, address, e-mail address, affiliated organization or company name, bi
rth date, medical device serial number, phone number, profession or specialty, d
iagnosis, treatment or condition, or other specific types of personal informatio
n.
What Personal Information Do We Collect, and How?

We collect personal information in a variety of ways, including through personal

contact, via our Web sites and the Internet, over the telephone, through corres
pondence and from other sources, through our employees and their attendance at i
ndustry events, and, where necessary to identify patients, through third parties
who have your authority to disclose such personal information to us or where we
are required to do so by law.
We collect, retain, and use information submitted to us to register and track pa
tients who have certain St. Jude Medical devices implanted. We are required to t
rack these devices in accordance with the U.S. Federal Food, Drug and Cosmetic A
ct and various U.S. Food and Drug Administration regulations. In the United Stat
es, the Health Insurance Portability and Accountability Act (HIPAA) provides tha
t no patient consent or authorization is required to disclose information to med
ical device manufacturers for tracking purposes. We will also use such informati
on if you are outside the United States and have provided your explicit consent
for us to use that information as outlined in this policy or if we are under a l
egal obligation to do so.
Generally, where we request personal information from you, we will explain the p
urpose of its collection and use and to whom it may be disclosed at the time we
collect it. If you decide to withhold particular information, it may limit our a
bility to provide you with the services or products you requested. If you believ
e that a third party has disclosed your personal information to us without your
consent to do so, please contact that third party. If they do not adequately res
pond to your inquiries, please let us know.
The personal information collected by us shall be limited to those details neces
sary for the purposes identified to you.
Is Personal Information Collected from IP Addresses and Through the Use of Cooki
es?
Through the use of Web site cookies, we monitor which pages of our Web site visi
tors view and how often visitors view them. Through the use of these cookies, we
are able to capture standard Web traffic information such as time, date, IP add
ress, and browser, but in most circumstances the information captured cannot ide
ntify you as an individual. We use this information to improve the quality of ou
r service and help us better understand how our visitors interact with us.
Cookies are small data files that are sent to your browser and placed on your co
mputer's hard drive when you visit a Web site. Cookies store your preferences an
d other information on your computer and save you time on subsequent visits by e
liminating the need to repeatedly enter the same information. You can set your b
rowser to accept or decline cookies. Some sections of our Web site may not work
properly if you decline cookies. If you would like further information about man
aging and disabling cookies, you can refer to your browser's help section or use
r guide. Alternatively, the Interactive Advertising Bureau has produced a guide
(see www.allaboutcookies.org) that explains to users how cookies work and can be
managed.
Why Do We Collect Personal Information?
We use and disclose personal information only for the purposes that we have disc
losed to you, except as otherwise permitted or required by law. If for any reaso
n your information is used or disclosed for a materially different purpose, we w
ill obtain your consent before we proceed.
In general, we collect, use, and disclose personal information to meet the needs
of our customers and for the following business purposes:
recording and reporting on our products and related medical conditions, incl
uding reporting to regulatory and medical authorities and recording and respondi

ng to product inquiries, feedback, and complaints;

understanding our customers and their needs;
learning about our markets and improving our products and services;
shipping product information or providing services to our customers;
complying with our regulatory, legal, and ethical obligations, including rec
ording and reporting on any adverse events;
ensuring and protecting health and safety;
contacting you (including by way of e-mail), including:
in response to your inquiries and to respond to your questions and comme
nts and to safeguard your interests;
to provide you with information about our products and services, or thos
e of others, that we consider of interest to you;
to meet legal requirements;
in the case of health care professionals (HCPs):
in connection with research and clinical trials that the HCP is invo
lved with or that we believe the HCP may be interested in being involved with;
to provide education, training, evaluation, and/or demonstration of
products;
to provide samples;
in connection with conferences, symposia, expert panels, or other ev
ents with which we are involved or with which we believe a HCP may wish to be in
volved; and
for complying with our corporate policies for expense reimbursement
that require us to record the names and affiliations of attendees;
in the case of patients:
in connection with our patient programs, research, and clinical tria
ls;
to register and track patients who have been implanted with our devi
ces, where required by law or where we have obtained explicit consent; and
to communicate with the hospital, medical practitioner, or the healt
h insurer of the patient in relation to the patient's care;
in the case of our contractors, distributors, or commissioned agents:
to our related entities in the United States and worldwide in connec
tion with our Business Purposes (This may involve those entities providing that
information to their third-party suppliers
subject to obligations of confidentiality);
protecting our rights and property;
disclosing to external service providers that we engage to assist us in
the conduct of our business (these service providers will only be permitted to u
se that information
for the purpose of assisting us), including but not limited to service p
roviders assisting us with expense reports of employees.
How Do We Use and Disclose Your Personal Information?
We are responsible for personal information in our possession or custody, includ
ing personal information that we may transfer to third parties for processing, i
ncluding storage.
In the event we disclose personal information to our service providers, we requi
re our service providers to agree to contractual requirements that are consisten
t with our privacy and security policies. We prohibit our service providers from
using personal information except for the specific purpose for which we supply
it to them, and that they comply with legal requirements applicable to the perso
nal information in question.
We may also use and disclose personal information as authorized by you when you
provide that information to us.
We may also use your personal information and disclose your personal information

to third parties in connection with the proposed or actual financing, insuring,

sale, securitization, assignment, or other disposal of all or part of our busin
ess or assets (including accounts) for the purposes of evaluating and/or perform
ing the proposed transaction, and you consent to such disclosure. These purposes
may include, as examples, permitting such parties to determine whether to proce
ed or continue with the transaction, fulfilling any reporting or audit requireme
nts to such parties, and/or disclosing personal information as part of concludin
g a sale or transfer of assets. Our successors and assigns may collect, use, and
disclose your personal information for substantially similar purposes as descri
bed in this privacy policy. In the event the transaction does not go through, we
will require, by contract, the other party(ies) to the transaction not to use o
r disclose your personal information in any manner whatsoever for any purpose, a
nd to return or destroy such personal information.
St. Jude Medical, and our affiliates, may disclose personal information as requi
red by law, regulation, warrant, subpoena, court order, or regulator or law enfo
rcement agency or personnel, as well as in respect to a criminal investigation o
r to meet government tax reporting requirements. In some instances, such as a le
gal proceeding or court order, we may also be required to disclose certain infor
mation to government authorities. Only the information specifically requested is
disclosed and we take precautions to verify that the authorities making the req
uest have legitimate grounds to do so. We also may release certain personal info
rmation when we believe that such release is reasonably necessary to protect the
rights, property, and safety of others and ourselves.
There are some situations in which we are legally permitted to disclose personal
information, such as employing reasonable and legal methods to enforce our righ
ts or to investigate suspicion of illegal activities.
Except as set forth herein, St. Jude Medical does not disclose sell and/or trade
customer lists to third-party companies or organizations.
Childrens Privacy
This site is not targeted to children under the age of 18 and St. Jude Medical d
oes not intentionally collect personal information from such children. If we dis
cover that a child has provided us with personal information online through this
Web site, we will take reasonable steps to delete this information. If you beli
eve we may have accidentally received personal information from a child under th
e age of 18, please immediately contact us at privacy@sjm.com.
How Can You Opt Out Of Marketing Mailings?
We may from time to time send you marketing material that we believe may be of i
nterest to you. You have the right to ask us not to process your personal inform
ation for marketing purposes. We will usually inform you (before collecting your
information) if we intend to use it for such purposes or if we intend to disclo
se your information to any third-party for such purposes. If you no longer wish
to receive information from us, please use the opt-out or unsubscribe link on the email to remove yourself from the mailing list. You may also elect not to receive
such materials by:
checking certain boxes on the forms we use to collect your information; or
contacting us at the following address:
Chief Privacy Officer
St. Jude Medical, Inc.
One St. Jude Medical Drive
St. Paul, MN 55117 USA
Please note that we may be required to send certain information to you under a l
egal, regulatory, or ethical requirement.

Where We Store Your Personal Information

Generally, the personal information that we collect from you will be transferred
to and stored in the United States. The United States may have different levels
of privacy protection than apply in your country. Your personal information may
also be processed by staff, in the United States, working for us or for one of
our related companies, affiliates, or suppliers. Such staff may be engaged in, a
mong other things, the provision of support services. By submitting your persona
l information via our Web site, you agree to any such transfers, storage, or oth
er processing. We will take all steps reasonably necessary to ensure that your p
ersonal information is treated securely and in accordance with this privacy poli
cy.
It is important to note that some or all of your personal information provided t
o third-party service providers may be held by them in countries other than your
own, including in particular the United States. You acknowledge and understand
that your personal information will be subject to the applicable laws of each su
ch jurisdiction, which may not provide the same protection as your country of re
sidence. For example, government entities in the United States, among other coun
tries, may have certain legislative rights to access your personal information.
If you would like access to written information about our policies and practices
with respect to service providers outside your jurisdiction, you may e-mail pri
vacy@sjm.com. Our Chief Privacy Officer or representative will address your ques
tions about the collection, use, disclosure, or storage of personal information
by our service providers worldwide.
Security of Your Personal Information
We take reasonable steps and utilize no less than industry standard security saf
eguards, including maintaining physical, electronic, and procedural safeguards i
n compliance with industry standards and
applicable laws to protect personal information from loss and unauthorized acces
s, modification, disclosure, inappropriate alteration, or misuse.
Electronic customer files are kept in a highly secure environment with restricte
d access. Paper-based files are stored in locking filing cabinets. Access is res
tricted to authorized employees who have a legitimate business purpose and reaso
n for accessing personal information.
We manage our server environment appropriately and our firewall infrastructure i
s strictly adhered to. Our security practices are reviewed on a regular basis an
d we routinely employ current technologies to ensure that the confidentiality an
d privacy of your information is not compromised.
For those areas of our Web site collecting sensitive information, our Web site u
ses Secure Socket Layer (SSL) and 128 bit encryption technologies to enhance sec
urity when you visit the secured areas of these Web sites. SSL is the industry s
tandard tool for protecting and maintaining the security of message transmission
s over the Internet. When you access your accounts or send information from secu
red sites, encryption will scramble your data into an unreadable format to prote
ct it from interception by others.
To safeguard against unauthorized access to your accounts, you are required to "
sign-on" using a user ID and a password to certain secured areas of St. Jude Med
ical Web sites. Both user ID and password are encrypted when sent over the Inter
net. If you are unable to provide the correct password, you will not be able to
access these sections. You are required to keep your password and user ID secure
and not provide that information to third-parties. If you suspect that someone
is using your user ID or password, please report it
immediately to our Chief Privacy Officer by sending an e-mail to privacy@sjm.com
. You have an active role in protecting your own information. Please safeguard y

our environment and use reasonable steps to ensure that others do not access you
r information through your computer. Remember to logout to keep your information
secure. St. Jude Medical will not be liable for disclosures of your personal in
formation due to errors in transmission or unauthorized acts of third-parties.
When you call one of our division customer service centers for patient and produ
ct questions, you will be required to verify your identity by providing personal
information. We will only use this information in order to identify you.
While we take reasonable steps to protect personal information as outlined in th
is policy, we cannot ensure or warrant our ability to do so because no internet
transmission is 100% secure. Please consider this when sending information to us
by e-mail.
Access and Accuracy
Where allowed by law, you may request access to personal information we hold abo
ut you by sending an email to privacy@sjm.com. We will process that request in l
ine with any local laws and our policies and procedures in place for dealing wit
h such requests and will respond to you within a reasonable time frame.
There may be circumstances where we are unable to provide access to your persona
l information. We may deny or restrict access for legally permissible reasons, s
uch as situations where the information contains references to other individuals
and is not reasonably severable, or where it cannot be disclosed for legal, sec
urity, or commercial proprietary reasons. We will advise you of any reason for d
enying or restricting an access request.
We shall make every reasonable effort to ensure your personal information is mai
ntained in an accurate, complete, and up-to-date form. If you believe that we ha
ve inaccurate, incomplete, or out-of-date personal information about you, you ma
y ask us at any time to correct that information. When an individual successfull
y demonstrates the inaccuracy or incompleteness of personal information held by
us, we will correct or update the information as required.
Please note that before we are able to provide you with any information or corre
ct any inaccuracies, we may ask you to verify your identity and to provide other
details to help us to respond to your request. We will only use this informatio
n in order to verify your identity. Where appropriate, we will communicate these
changes to other parties who may have received incorrect information from us.
In the course of daily operations, access to personal information is restricted
to authorized employees who have a legitimate business purpose and reason for ac
cessing it. For example, when you contact us, our designated employees will acce
ss your information to verify who you are and to assist you in fulfilling your r
equests.
As a condition of their employment, all employees of St. Jude Medical are requir
ed to abide by the privacy standards we have established. Employees are trained
about the importance of privacy including prohibiting the disclosure of any cust
omer information to unauthorized individuals or parties.
Unauthorized access and/or disclosure of personal information by an employee of
St. Jude Medical is strictly prohibited. All employees are expected to maintain
the confidentiality of personal information at all times and failure to do so wi
ll result in appropriate disciplinary measures being taken, which may include di
smissal.
Subject to applicable business, legal, or regulatory requirements, we securely d
estroy, erase, or de-identify personal information when it is no longer required
to fulfil our services and commitments to you or to enforce our rights or meet

our obligations.
Links to Other Web Sites
St. Jude Medical Web sites may contain links to other third-party Web sites that
are not governed by this privacy policy. Although we endeavor to link only to W
eb sites with high privacy standards, our privacy policy will no longer apply on
ce you leave any of our Web sites.
Links to other sites are provided for information only and do not constitute end
orsements of those other sites. St. Jude Medical is not responsible for the cont
ent of links or third-party sites and does not make any representation regarding
their content or accuracy. Your use of third-party Web sites is at your own ris
k.
Additionally, we are not responsible for the privacy practices employed by other
third-party Web sites. Therefore, we suggest that you examine the privacy polic
ies of those Web sites to learn how your
information may be collected, used, shared, and disclosed by the third-party in
question.
Updates to This Policy
This policy will be published on all of our corporate Web sites worldwide. St. J
ude Medical may amend this policy from time to time. The revisions will take eff
ect on the date of publication of the amended policy, as stated.
Through a notice on our Web site, we will notify you of any material changes to
this policy, and draw your attention to the changes made. In the event that the
changes we make to the policy are substantial and/or affect the personal informa
tion we have already collected in accordance with this policy, you will be entit
led to withdraw your consent to such personal information handling practices pro
vided such consent is not necessary for us to provide to you the services or pro
ducts you have requested. You may notify us of your desire to withdraw consent b
y contacting our Chief Privacy Officer as noted above.
The current applicable version of this policy is accessible at http://www.sjm.co
m/corporate/policies/privacypolicy.aspx.
Complaint about an Interference with Privacy and Contact Information
If you consider that any action taken by us breaches this privacy policy or any
applicable local law, you may
make a complaint by contacting us:
Chief Privacy Officer
St. Jude Medical, Inc.
One St. Jude Medical Drive
St. Paul, MN 55117 USA
or via e-mail at privacy@sjm.com
We will endeavor to respond within an appropriate timeframe.
Please address all requests or questions about how we deal with your personal in
formation or this policy to our Chief Privacy Officer at privacy@sjm.com.
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ST. JUDE MEDICAL and the nine-squares symbol are trademarks and service marks of
St. Jude Medical, Inc. and its related companies.
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