Medtronic
Health Care
68
out of 100. Number 59 of 512, counting from the worst.
Where Medtronic does well
- Renewals 3 of 20. Few problems found.
- The main corporate Medtronic privacy notice states: 'Medtronic does not sell your personal data for money or other consideration, nor share it for direct or behavioral marketing purposes, with unrelated third parties, except as described in the cookies and similar technologies paragraph.'
- Medtronic explicitly commits not to reidentify deidentified HIPAA-protected health information: 'Medtronic does not, and will not permit others to, reidentify deidentified PHI except as required by applicable law or as directly consented to by the subject of that PHI.'
- The corporate notice expressly excludes PHI from its scope ('This notice does not apply to our data processing activities and practices for Protected Health Information (PHI), which is regulated under [HIPAA]'), so health data gets the stricter HIPAA Notice of Privacy Practices instead.
- MiniMed honors opt-out preference signals (Global Privacy Control) as valid sale/sharing opt-outs, and US residents can file privacy-rights requests without creating an account (also via a toll-free number 1-866-639-6907).
If you use Medtronic's InPen insulin-pen app, you give up your right to a jury trial and your right to join a class action.
The fine print
6 clauses and findings from the draft archive, dated 1 October 2026. The plain English comes first; the small print is the company's own words. None of these has been checked yet.
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If you use Medtronic's InPen insulin-pen app, you give up your right to a jury trial and your right to join a class action. Any dispute goes to private AAA arbitration, on an individual basis only — with no opt-out offered anywhere in the clause. Discovery is also 'expressly limited' in the arbitration.
WAIVER OF JURY TRIAL. EACH OF US WAIVES OUR RESPECTIVE RIGHTS TO A TRIAL BY JURY OF ANY CONTROVERSY, DISPUTE, OR CLAIM... ANY CLAIM SHALL INSTEAD BE DETERMINED BY BINDING ARBITRATION... (c) WAIVER OF "CLASS ACTION" CLAIMS. ANY ARBITRATION PROCEEDING CONDUCTED UNDER THIS AGREEMENT SHALL BE LIMITED TO OUR INDIVIDUAL CLAIMS AGAINST EACH OTHER, AND NO CLAIM OF ANY OTHER PARTY SHALL BE SUBJECT TO ARBITRATION IN SUCH ARBITRATION PROCEEDING ON ANY BASIS WHATSOEVER... EACH PARTY THEREFORE WAIVES ITS RIGHT TO JOIN ITS CLAIM WITH CLAIMS OF ANY OTHER PARTY.
Medtronic Diabetes Terms of Use incl. InPen End User License Agreement, §36
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Medtronic's diabetes arm admits it sells and shares users' identifiers, browsing activity, and behavioral inferences with third-party marketing and analytics companies — and explicitly warns that this sharing could imply you have a health condition or use a medical device. The only opt-out is toggling cookies off.
Accordingly, we Sell and Share and in the past 12 months have Sold and Shared, identifiers, such as IP addresses and other device identifiers, internet or other electronic network activity information, and inferences to third party marketing and analytics providers for advertising and marketing, including interest-based marketing, and analytics purposes... because this disclosure of personal information to third party marketing and analytics providers could potentially suggest that you have a particular health condition or are using a particular medical device, we provide the following notice for compliance with the U.S. Privacy Laws: NOTICE: We may sell your sensitive data.
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Medtronic can rewrite the InPen terms unilaterally, and the new terms take effect the moment they're posted — you 'agree' simply by continuing to use the app that doses your insulin. The corporate website terms work the same way: 'By using this website, it means you accept the most recent version of the terms of use.'
We may change this EULA from time to time by posting a new version at https://www.medtronicdiabetes.com/terms-of-use (Exhibit A) which is effective upon posting... Continued use of the InPen System following notice or posting of any such changes will indicate your acknowledgement of such changes and will be your agreement to be bound by the revised EULA.
InPen End User License Agreement, §18 'Changes to this EULA'
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Medtronic can cut off your access to the InPen insulin-dosing app at any time, for any reason or no reason, and accept zero liability for it — even though the app calculates insulin doses and reminds you to take them.
We may terminate your use of the InPen System and/or Support Services and (if applicable) your subscription at any time. Neither party needs any reason for its termination. YOU AGREE THAT WE ARE NOT LIABLE TO YOU OR ANY OTHER PARTY FOR ANY TERMINATION OF YOUR ACCESS TO AND/OR SUBSCRIPTION TO THE INPEN SYSTEM OR SUPPORT SERVICES.
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Even if you get past the arbitration clause, you have just one year (not your state's normal statute of limitations) to bring any claim, and you must bring it in Minneapolis, Minnesota — Medtronic's backyard.
Any claim arising from or in connection with the EULA may only be brought in Minneapolis, Minnesota, and must be commenced no later than one year after the date the claim arises.
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Your medical-institution service data can be repurposed for Medtronic's business analytics, benchmarking, and market research based on the institution's authorization — not your direct consent. You never personally agree to this secondary use.
With the authorization of your medical institution, the data obtained as part of the services provided to your medical institution may be further used to support and improve those services, including to improve and develop Medtronic products and services, to conduct benchmarking, business analytics or market research, to train and educate Medtronic personnel or healthcare professionals, or to support regulatory filings and the reimbursement of Medtronic products and services.
How these were found
Documents read via browser_open on official Medtronic domains on Oct 1, 2026. (a) Medtronic Diabetes Terms of Use + InPen EULA page is headed 'Updated on October 8, 2025' but the EULA body itself is dated November 22, 2021; arbitration (§36), unilateral-change (§18), termination (§24), and 1-year-limitation (§35) clauses are all from that InPen EULA text. (b) The main medtronic.com corporate privacy notice (secondary-use, no-sale, deidentification, retention) was read from the 'Previous Privacy Notices' archive page (https://www.medtronic.com/en-us/privacy-notice/previous-privacy-notices.html) — i.e., a prior version of the notice; the current notice may differ. (c) The main medtronic.com Terms of Use (Jan 26, 2015) appear stale/unrevised in 11 years but are still the live page. (d) The Medtronic Diabetes terms were read on origin.medtronicdiabetes.com (Medtronic's CDN origin host), which serves the same terms content referenced at www.medtronicdiabetes.com/terms-of-use. (e) No mirrors used; no auto-renew traps found — Medtronic sells devices rather than subscriptions, so the autorenew score reflects only the InPen subscription refund/no-refund rule.
These notes come from the original draft and are not independent verification.