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Introduction

Solventum and its subsidiaries and affiliates (“Solventum,” “we,” “our” or “us”) respect your right to privacy. This Privacy Statement (“Statement”) describes the Personal Data we may collect about you; how we use, disclose and otherwise process it; how we protect it; and the rights and choices you may have regarding your Personal Data. For more information about our processing and the rights that may available to you in the jurisdiction where you reside, see “Additional Information for Residents of Certain Jurisdictions” below.

This Statement applies to the Personal Data (as defined below) that we process when you use this website (“Website”), our mobile applications (“Apps”), and our other websites and services or products that reference this Statement (collectively, our “Services”), and when you otherwise interact with us as described in more detail below. Unless you are in a jurisdiction where this is not permitted, your use of our Website, and any related dispute over privacy, is subject to our Terms of Use. Where required by applicable law, we will not collect, use, or disclose your Personal Data without first obtaining your consent. 

Throughout this Statement, we use the following defined terms:

  • "Solventum," "we," "us," or "our" refers to the entity that is responsible for the collection and use of your Personal Data (also referred to as a data controller), which is usually the entity that originally obtains your Personal Data. For a list of Solventum data controllers and contact details by country, please click here.
  • "Personal Data" refers to any information relating to an identified or identifiable individual, or as related terms, such as "personal information," are defined under applicable law.

Our Statement is organized in the following sections. 

  • Scope
  • Personal Data Solventum Collects
  • How Solventum Collects Your Personal Data
  • How Solventum Uses Your Personal Data
  • How Solventum Discloses Your Personal Data
  • Cookies and Similar Automated Data Collection Technologies
  • Your Rights
  • Cross-Border Transfers
  • Protecting Personal Data
  • Links to Third Party Internet Sites and Plugins
  • Retention of Your Personal Data
  • Children
  • Questions about this Statement
  • Changes to this Statement
  • Additional Information for Residents of Certain Jurisdictions
    • Supplemental Information for Residents of Canada
    • Supplemental Information for Residents of Certain U.S. States (including California)
    • Supplemental Information for EEA, UK and Swiss Residents
    • Supplemental Information for Residents of the People’s Republic of China
  • Other privacy notice
Scope

This Statement applies to Personal Data that we may process through your interactions with us:

  • Through online activities and Services we offer (including our Websites, Apps, social media pages, webinars, digital events, and other online Services);

  • Through third-party sources, including ad networks;

  • When we provide Services directly to you and in other situations where you interact with us, including but not limited to interacting with us through our telephone customer service centers, through email, chat, SMS/text or social media direct messages, or by visiting our sites and offices or our events (e.g., tradeshows and conferences);

  • When we provide Services to you or your doctor, hospital, medical treatment or scanning facility, or other healthcare provider (collectively, “Healthcare Provider”) or, if you are a Healthcare Provider, your patients;

  •  Related to activities we undertake in recruiting participants for participation in clinical trials or activities related to identifying and contracting with study investigators and their staff;

  •  When you interact with us in a professional capacity, for example, if you are a former, current, or prospective customer, distributor, or other business partner (collectively, “Business Partners”) as well as our suppliers and vendors; or

  •  Anywhere this Statement is posted or referenced.

Some of our Services are regulated by certain state and federal laws, including the Health Insurance Portability and Accountability Act ("HIPAA"), and may have specific privacy practices ("Specific Privacy Notices"). When a Specific Privacy Notice exists, the content of the Specific Privacy Notice applies to your use of that specific product and/or service. For example, to the extent we collect and use your Personal Data pursuant to HIPAA (“Protected Health Information” or “PHI”), our HIPAA Notice of Privacy Practices will govern. When we act as a business associate to a covered entity (such as certain health care providers or health plans) or another business associate under HIPAA, our uses and disclosures of PHI are subject to the covered entity’s notice of privacy practices and our business associate agreements with our customers.

Some of our Services are intended for use by our Business Partners, including our business customers (“Solventum B2B Services”), such as Healthcare Providers. When Business Partners purchase and use our Solventum B2B Services, we may process your Personal Data at their direction and on their behalf, as a service provider, and your use of Solventum B2B Services is administered by that company, our Business Partner. In such cases, the privacy policies of the respective Business Partner apply to the processing of your Personal Data and not this Statement. If you have any privacy questions related to your Personal Data processed related to a Solventum B2B Service, you should contact the relevant Business Partner directly.

Personal data Solventum collects

When you interact with us, we may collect Personal Data such as:

  • Contact Information, including your name, company name, job title, address, e-mail address, and phone number.

  • Device Information, including browser and device type, IP address, internet service provider, and other technical information about your device.

  • Website Interactions, including information about your interactions with our Website (including features on our site, like our chat feature and the video content that we make available), such as referring websites, pages visited, links or buttons clicked, or information about your preferences, such as your preferred methods of communication and product types in which you are interested.

  • Transaction Data, including purchase and order history, as well as payment or other financial information if you make purchases, such as credit card or account information or tax identification number.

  • Communication Records, including call recordings and transcriptions, email exchanges, text details, and chat contents and logs from your communications with us, which we may keep as records of those conversations.

  • Log-in Information, including, if applicable, social media account information for login purposes.

  • Social Media Information, including social media name, profile, and any direct messages exchanged with us.

  • Clinical Trial Information, including potentially health, genetic or biometric information, relating to your use of a Solventum product in the context of a clinical trial or study involving that product.

  • Health and Safety Information, including information about adverse events or other health and safety incidents involving the use of Solventum products.

  • Other information you voluntarily provide to Solventum, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our Services, and demographic information.
How Solventum collects your personal data

When you interact with us, we may collect Personal Data directly from you, automatically from your browser or device, and from other sources such as our Business Partners and other third parties.

 

Personal data collected directly from you

We collect Personal Data you choose to provide to us on our Website, through our Apps, or when you contact us by phone or email. For example, we may collect Personal Data from you when you:

  • Purchase products through our website or download our Apps;

  • Register or create an account with us;

  • Engage with us in response to our marketing activities, including by expressing an interest in our Services through a web form, participating in a promotion or responding to a voluntary survey, attending our marketing events, or subscribing to our email updates and newsletters;

  • Contact customer service or make use of our customer support tools;

  • Connect with, link to, or "share" our website via social networking sites; or

  • Provide ratings, reviews, or feedback for our Services.

If you provide us with any Personal Data relating to a third party, you represent that you have the authority to do so and to permit us to use the information in accordance with this Statement.

 

Personal data collected through automated means

We automatically collect information from you when you interact with us and use our Services, such as:

  • Device and browser information, such as device type, browser type, IP address, operating system, device identifier, and Internet service provider, as well as other information such as general location information, domain name, page views, a date/time stamp, referring and exiting URLs, language, clickstream data and similar device and usage data.

  • Information about how you interact with us, such as your usage of Solventum Websites and Apps and how you interact with our digital advertisements and promotions, such as video and other content viewed or downloaded and information about your viewing, features used, links clicked, keystrokes and mouse clicks, Solventum promotional emails opened, and dates and times of interactions.

Our Business Partners and other third parties may also use these technologies to collect information about your online activities. For more information, see the section below on Cookies and Similar Automated Data Collection Technologies.

 

Information from business partners and other third parties

Solventum may collect, use or supplement the Personal Data we have about you with information obtained from other publicly or commercially available sources, such as our Business Partners, suppliers, vendors and other third-party sources (e.g., public databases and social media platforms).

For example, we may use such third-party information to confirm contact or financial information, or to better understand your interests by associating demographic information with the information you have provided.

How Solventum uses your personal data

We use your Personal Data to:

Develop and manage our relationships with you and our Business Partners. This may include:

  • Delivering services or carrying out transactions that you or our Business Partners have requested;
  • Providing information about Solventum products, services, transactions, and advertisements, that may be of interest to you;
  • Providing you and our Business Partners a more consistent experience in interacting with Solventum, including by learning more about you and how you use and interact with Solventum’s Services; and
  • Planning, managing, and performing under our contractual relationships with you, our Business Partners, vendors and suppliers.

Communicate with you or your company. This may include:

  • Informing You of Solventum’s products, services, events, programs, competitions and promotional activities that may be of interest to you or your company;
  • Providing information about relevant Solventum products, services, and transactions, including, for example, pricing information, technical data, invoice, shipping, or production information, warranty or recall information, or information about product or service improvements; 
  • Responding to questions or inquiries that you make, including customer service requests; and
  • Inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.

Provide and improve our Services. This may include:

  • Customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use;
  • Maintaining the security of and otherwise protecting them;
  • Developing new Solventum’s Services, as well as conducting trials and studies of new products using human subjects; and
  • Performing data analytics.

Address legal issues. This may include:

  • Complying with our obligations to retain certain business records for minimum retention periods;
  • Establishing, exercising, or defending legal claims;
  • Complying with laws, regulations, court orders, or other legal process;
  • Detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, adverse events and other health and safety incidents involving our products, violations of law, or other misuse of Solventum’s Services; and
  • Protecting Solventum’s rights or property, or your or others’ health, safety, welfare, rights, or property

Solventum may also use your Personal Data for other uses consistent with the context in which the information was collected or with your consent.

Solventum may anonymize, aggregate or de-identify any of the information we collect from you and, where permitted by applicable law, use it for any purpose, including for research, product-development, and service and product quality review purposes. Such information will not identify you individually, and we will maintain and use the information in deidentified form and will not attempt to reidentify the information.

How Solventum discloses your personal data

We may disclose your Personal Data to the following recipients and for the purposes described below. In each case, we will take appropriate steps (including obtaining your consent where required by applicable law) to protect your Personal Data.

Solventum affiliates. Our Solventum affiliates will use your Personal Data in a manner consistent with this Statement, any applicable Specific Privacy Notices, and all applicable laws.

Service providers. We may disclose your Personal Data to contractors, service providers and other vendors we engage to perform support services for us, such as hosting providers, payment processors, customer service agencies, analytics service providers and ad companies.

Business partners. We may disclose your Personal Data with third parties who partner with us to support our products, services and marketing efforts to our customers; to our partners who provide us with analytics services (for example, to better understand our customers); and to our authorized partners and service providers.

In connection with business transfers. We may disclose your Personal Data with third parties (including potential or prospective buyers, sellers, lenders and their respective affiliates, agents, advisers and representatives) in connection with the actual or contemplated sale, purchase, merger, reorganization, liquidation, dissolution or other disposal of assets or interests of Solventum or a Solventum business unit.

With your consent. We may disclose your Personal Data with your permission or at your request.

To comply with law or to protect. We may disclose your Personal Data with third parties when we have a good faith belief that disclosure is necessary:

  • to comply with a law, regulation, court order, or other legal process;
  • to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of Solventum Services;
  • to protect the health, safety, welfare, rights, or property of you, our customers, the public, Solventum, or others; or
  • under similar circumstances.

In the aggregate / de-identified. To the extent permitted by applicable law, Solventum may share anonymized, aggregated or de-identified information internally and with third parties for any purpose. Such information will not identify you individually.

Cookies and similar automated data collection technologies

Cookies. We and our Business Partners may collect information about you by using cookies, web beacons, pixel tags, session replay and other similar automated data collection tracking technologies (collectively, "Cookies"). A Cookie is a bit of data that we can send to your browser when you link to our Website or Apps.

We use Cookies for a variety of reasons, including to help us gather statistical information about how visitors use the Websites and Apps, and to improve your experience, and maintain security. Cookies also help us deliver a personalized experience on our Websites and Apps. We engage third parties to help us in these activities, and these third parties may collect your information over time and across our Websites (and third party sites) in order to associate different devices you use and further gain insights into the goods and services that may interest you.

For more information on the Cookies we use or your choices related to them, please visit our Cookie Policy.

Do Not Track Browser Settings. Certain web browsers and other programs may transmit “opt-out” signals, such as the Global Privacy Control (or GPC) signal (“GPC Signal”), to websites with which the browser communicates. For users that access our websites from U.S. states, we will recognize and apply the GPC Signal to deactivate all of the cookies for that website, except for cookies that are necessary for the website to operate (“Strictly Necessary Cookies”). You can determine if your browser GPC Signal has been recognized by clicking on the “Your Privacy Preferences” link in the footer of the Website, where you will see the message “You have opted-out” under Manage Preferences.

Note that if you come back to our Websites from a different device or use a different browser on the same device, you will need to enable GPC or set your cookie preferences for each browser and device you use to access our Websites and Services. More information about GPC is available at: https://globalprivacycontrol.org/.

Mobile Device Settings. You may use mobile device settings to limit mobile tracking technologies and associated activities. For instance, Android users can visit Google settings > Ads > Reset advertising ID to adjust or reset the advertising identifiers on their mobile device in the device settings. Apple users can go to settings > Privacy & Security > Tracking, and turn off “tracking” to limit apps from tracking their activities across apps and websites for targeted advertising.

Your rights

Subject to certain conditions and exceptions, and depending on the applicable laws in your jurisdiction, you may have the right to make the following requests with respect to your Personal Data, free of charge. We will not discriminate against you for exercising any of your rights by clicking here or submitting an email to privacy@solventum.com.

Access / Copy: You may request to (i) access specific pieces of your Personal Data that we maintain, and (ii) that we provide your information in a portable format to you or a third party (i.e., the right to data portability).

Know: You may request to know certain information about the Personal Data that we process about you, including the:

  • Purposes for our collection, use, disclosure and other processing of Personal Data;
  • Categories and specific pieces of Personal Data collected (and under CCPA, the categories ‘sold’ to or ‘shared’ with third parties);
  • Categories of sources from which the Personal Data is collected;
  • Business and/or commercial purpose for collecting your Personal Data;
  • The categories of third parties to whom we disclose Personal Data (and under CCPA, the categories of third parties to whom we ‘sell’ or ‘share’ Personal Data);
  • Categories of Personal Data that we have disclosed to third parties for a business purpose; and
  • The consequences of not granting consent, or withdrawing consent, to our processing of your personal information.

Correct: You may request correction of your Personal Data if it is inaccurate or incomplete.

Delete: You may request deletion of your Personal Data (i.e., the “right to be forgotten”).

Object or Restrict: You may object to or restrict our processing of your Personal Data, including to:

  • The “sale” (as such term is defined under applicable law, including the CCPA) of your Personal Data;
  • The processing your Personal Data for direct marketing or targeted advertising purposes (or in California, the right to opt out of “sharing”, as defined under the CCPA);
  • The processing of your Personal Data on a ‘legitimate interest’ basis under the GDPR;
  • The use of profiling or automated decision-making which might significantly affect you;
  • Restrict (or limit) our use or disclosure of your sensitive Personal Data; and
  • If we are processing your Personal Data based on your consent, to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of our processing before your withdrawal.

De-register an account: You may request de-registration of any account you maintain with us, if applicable.

Exercising your rights

You or (where permitted by applicable law) your authorized agent may exercise your rights by submitting an email to privacy@solventum.com or by contacting us (toll free in the United States) at 1-855-423-6725. Before responding to your request, we will first take steps to verify your request by matching the Personal Data you provide to us with the information we have in our records. Your request must provide sufficient information for us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative (e.g., by completing all required fields on our request form. We may, after receiving your request, require additional information from you (or your authorized agent) to honor your request and verify your identity. For more information on how you can exercise the rights available to you in certain jurisdictions, see “Additional Information for Residents of Certain Jurisdictions” below.

Please note that for Personal Data that we process on behalf of a Business Partner, in our capacity as a processor or service provider, we will provide reasonable assistance to that Business Partner as necessary to enable them to respond to your requests to exercise your privacy rights. You should submit your request directly to the relevant Business Partner. 

 

Appeals

In some jurisdictions, you have the right to approach us or the competent data protection authority or equivalent regulatory body with requests or complaints in the jurisdiction(s) in which you reside, including with respect to cross-border transfers of your data.

If we deny your request to exercise a privacy right, you may request the right to appeal the decision to Solventum by contacting us or by submitting your appeal through our request form.

Cross-border transfers

Solventum operates in many countries. Your Personal Data may be transferred across international borders to other Solventum affiliates, or to other companies performing support functions on our behalf (as described in this Statement), located outside of the country where you live. Many of these transfers are to the United States. Regardless of where your Personal Data is processed, we ensure that the recipient offers an adequate level of protection and security, for instance by entering into the appropriate agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission or other applicable regulators or legislators. Where required by applicable law, we will only share, transfer or store your Personal Data outside of your jurisdiction with your prior consent.

Protecting personal data

Solventum maintains technical, physical and organizational measures designed to protect the confidentiality, security, and integrity of your Personal Data. Data protection measures include, but are not limited to, adoption of encryption tools and access controls. In addition, when we collect, maintain, access, use, or disclose your Protected Health Information (as defined under HIPAA), we do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, HIPAA.

Retention of your personal data

We will retain your Personal Data for as long as reasonably necessary or permitted in light of the purposes for which it was collected, and as described in this Statement or as otherwise disclosed to you at the time of collection. How long we keep your Personal Data varies and may depend on criteria that include:

  • the date of your last interaction with us;
  • whether retention is necessary or advisable due to applicable statutes of limitations, litigation, or other legal, regulatory, accounting or reporting obligations; or
  • any relevant retention requirements under applicable laws or in agreements with you or others.

If Personal Data is either (i) no longer necessary or relevant for the purposes for which it was collected, or (ii) no longer required to be retained by applicable laws, then we will take reasonable steps to have it deleted, destroyed, erased, or, if permitted by applicable law, aggregated, made anonymous, or de-identified.

If you have questions about our retention policies, please contact us at privacy@solventum.com.

Children

Solventum’s Websites and Apps are not directed to children under the age of sixteen (16), and we do not knowingly collect Personal Data from anyone under 16. If you believe we have unintentionally collected such information, please notify us as set out in the Questions about this Statement section below.

Questions about this statement

If you have any questions about this Statement or our use of your Personal Data, please email us at privacy@solventum.com or write to us at:

Solventum
3M Center
Mail Stop 275-6E-21
St. Paul, MN 55144-1000

Changes to this statement

We reserve the right to modify this Statement at any time. Where required by applicable law, we will seek your consent to any material changes. Any modifications will apply only to the Personal Data we collect after the posting.

You can determine when this Statement was last revised by referring to the Last Revised date set forth below.

Last Revised: April 1, 2024 

Additional information for residents in certain jurisdictions
 
Supplemental information for Canadian residents

In this section, we provide additional information to residents in Canada about your privacy rights under applicable privacy laws. This section does not address or apply to our collection and processing of data that is exempt from applicable law (such as information that is processed solely to communicate with a person about their employment or profession), or information about our employees, personnel, applicants and candidates. 

 

Quebec residents

If you are a resident of the province of Quebec, the following specific provisions ‎and ‎rights apply to you pursuant to the Act respecting the protection of personal information in the ‎private ‎sector, (CQLR c. P-39.1). Unless otherwise specified, these are in addition to the other provisions, rights and protections set out in this section, and which apply to all residents of Canada, and other rights set out in this Statement, which also may apply to residents of Canada.

Tracking and profiling technologies. Notwithstanding any provision to the contrary in this Statement, we will only collect your Personal Data using technology which allows you to be located, profiled or tracked (i) after having duly informed you of our intent to use such technologies and (ii) if you choose to activate such technologies. We may be unable to provide you with certain functionalities or services if you decide not to activate such technologies.

Privacy rights. In addition to the other rights set out above, under “Your Rights”, Quebec residents have the ‎right ‎to request, in certain circumstances, that we cease disseminating your Personal Data or to de-index any hyperlink that allows access to that Personal Data by technological means, if such dissemination contravenes applicable law or a court.‎

Exercising your rights. You may exercise your privacy rights as described above, under “Your Rights”. In accordance with the laws of the applicable jurisdiction, we may charge you a fee to access your Personal Data, and if so, we will give you notice in advance of costs for processing your access request.

 

Questions about this statement

If you have any privacy related questions or concerns not addressed in this Statement, please contact our Chief Privacy Officer, by phone at 1-800-265-1840 extension 2250, by email at privacy@solventum.com, or by mail at:

Solventum Canada Company
Attn: Chief Privacy Officer
300 Tartan Drive
London, ON N5V 4M9

Supplemental information for residents of certain U.S. States (including California)

In this section, we provide additional information to residents in certain U.S. states (including California) about the categories of Personal Data we collect about you and your privacy rights under applicable privacy laws including, where applicable, the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our collection and processing of data that is exempt from applicable law, or information about our employees, personnel, applicants and candidates. 

Our collection, use and disclosure of Personal Data varies based upon our relationship and interactions with you. The sections below briefly explain our collection, use, and disclosure of Personal Data and are followed by a chart showing how each category of Personal Data is typically used and disclosed by Solventum.

 

Collection of personal data

As described above, under “How Solventum Collects Your Personal Data”, how we obtain Personal Data (1) directly from you (for example, when you submit your Personal Data to us in a request form), (2) indirectly from you (for example, through Cookies used when you interact with our Website), and (3) from other sources (for example, public databases and social media platforms).

 

Use and disclosure of personal data

We use Personal Data for the reasons described above, under “How Solventum Uses Your Personal Data”, including customer service, communication, fulfillment, customer experience, personalization, direct marketing, promotions, and security and integrity. We disclose Personal Data to our affiliates, service providers, Business Partners, and for the purposes, including to support our business operations, described above, under “How Solventum Discloses Your Personal Data”.

The chart below generally describes each category of Personal Data that we collect, why we collect it, and who we may disclose it to, and reflects our practices during the past twelve (12) months. We collect the types of Sensitive Personal Information (as defined under the CCPA) about California residents for the purposes described in the table below; however, we do not collect, use, disclose or process Sensitive Personal Information about California residents beyond the purposes authorized by the CCPA (pursuant to Cal Civ. Code § 1798.121 and § 7027(m) of the CCPA regulations).

Certain privacy laws define a ‘sale’ as disclosing or making available to a third-party Personal Data in exchange for monetary or other valuable consideration, and ‘sharing’ broadly, including as disclosing or making available Personal Data to a third party for purposes of cross-context behavioral advertising. While we do not disclose Personal Data to third parties in exchange for monetary compensation, we may ‘sell’ or ‘share’ Identifiers and Internet and Electronic Network Activity Usage Information to advertising networks, data analytics providers and social networks. We do so to [improve and evaluate our advertising campaigns and better reach customers and prospective customers with more relevant ads and content]. We do not sell or share Sensitive Personal Information, nor do we sell or share any Personal Data about individuals who we know are under sixteen (16) years old.

Category of Personal DataPurpose of ProcessingCategories of Other Entities To Whom Information is Disclosed

Identifiers

Examples:

  • Name
  • Contact details
  •  Account or user name
  • Email address
  • IP address
  • Government-issued identifiers
  • Develop and manage relationships
  • Communicate with you or your company
  • Customize and personalize content
  • Engage in marketing and advertising
  • Provide, analyze and improve our Services.
  • Planning and managing events
  • Compliance and legal process
  • Security and protection of rights
  • General business and operations support
  • In accordance with your consent
  • Service providers including those that provide logistics, cloud solutions, payment processing, security, IT, quality assurance, and document exchange and collaboration services.
  • Advisors and agents including legal counsel and consultants.
  • Government entities including regulators and law enforcement.
  • Affiliates and subsidiaries
  • Advertising networks
  • Data analytics providers
  • Social networks
  • Internet service providers, operating systems and platforms
  • Business Partners
  • Others as required by law

Categories of Personal Data Described in Cal. Civ. Code § 1798.80

Examples:

  • Name
  • Account information
  • Postal address
  • Employment history
  • Payment information
  • Develop and manage relationships
  • Communicate with you or your company
  • Customize and personalize content
  • Engage in marketing and advertising
  • Provide, analyze and improve our Services.
  • Planning and managing events
  • Compliance and legal process
  •  Security and protection of rights
  • General business and operations support
  • In accordance with your consent
  • Service providers including training providers, verification providers, and consumer relationship management providers.
  • Advisors and agents
  • Government entities including regulators and law enforcement.
  • Affiliates and subsidiaries
  • Advertising networks
  • Data analytics providers
  • Social networks
  • Internet service providers, operating systems and platforms
  • Business Partners
  • Others as required by law

Commercial Information

Examples:

  • Records of products or services purchased, obtained, or considered
  • Purchasing or use histories or tendencies
  • Develop and manage relationships
  • Communicate with you or your company
  • Customize and personalize content
  • Engage in marketing and advertising
  • Provide, analyze and improve our Services.
  • Planning and managing events
  • Compliance and legal process
  • Security and protection of rights
  • General business and operational support
  • In accordance with your consent
  • Service providers
  • Advisors and agents
  • Government entities including regulators and law enforcement.
  • Affiliates and subsidiaries
  • Advertising networks
  • Data analytics providers
  • Social networks
  • Internet service providers, operating systems and platforms
  • Business Partners
  • Others as required by law

Characteristics of Protected Classifications Under California and Federal Law

Examples:

  • Gender
  • Date of birth
  • Citizenship
  • Marital status
  • Medical information
  • Disability status
  • Develop and manage relationships
  • Communicate with you or your company
  • Customize and personalize content
  • Provide, analyze and improve our Services.
  • Planning and managing events
  • Compliance and legal process
  • Security and protection of rights
  • General business and operational support
  • In accordance with your consent
  • Service providers
  • Advisors and agents
  • Government entities including regulators and law enforcement.
  • Affiliates and subsidiaries
  • Business Partners
  • Others as required by law

Internet and Electronic Network Activity Usage Information

Examples:

  • Browsing history
  • Clickstream data
  • Search history
  • Access logs
  • Interactions with our Website or Apps
  • Develop and manage relationships
  • Communicate with you or your company
  • Customize and personalize content
  • Engage in marketing and advertising
  • Provide, analyze and improve our Services.
  • Planning and managing events
  • Compliance and legal process
  • Security and protection of rights
  • General business and operational support
  • In accordance with your consent
  • Service providers including marketing providers and cloud providers
  • Advisors and agents
  • Government entities including regulators and law enforcement
  • Affiliates and subsidiaries
  • Advertising networks
  • Data analytics providers
  • Social networks
  • Internet service providers, operating systems and platforms
  • Others as required by law

Audio/Visual, Electronic, Thermal, Olfactory, and Similar Information

Examples:

  • Video recordings collected from visitors to our offices/premises
  • Voice recordings of customer support calls
  • Thermal screenings
  • Develop and manage relationships
  • Communicate with you or your company
  • Customize and personalize content
  • Planning and managing events
  • Security and protection of rights
  • General business and operational support
  • In accordance with your consent
  • Service providers
  • Advisors and agents
  • Government entities including regulators and law enforcement.
  • Affiliates and subsidiaries
  • Others as required by law

Geolocation Data

Examples:

  • This category contains data elements that allow location of the individual.
  • Develop and manage relationships
  • Communicate with you or your company
  • Customize and personalize content
  • Provide, analyze and improve our Services.
  • Compliance and legal process
  • Security and protection of rights
  • General business and operational support
  • In accordance with your consent
  • Service providers (including for inventory management)
  • Advisors and agents
  • Government entities including regulators and law enforcement.
  • Affiliates and subsidiaries
  • Data analytics providers
  • Internet service providers, operating systems and platforms
  • Business Partners
  • Others as required by law

Sensitive Personal Information

Examples:

  • Payment information in combination with any required security or access code
  • Precise geolocation
  • Personal Data collected and analyzed concerning a consumer’s health
  • Develop and manage relationships
  • Communicate with you or your company
  • Compliance and legal process
  • Security and protection of rights
  • General business and operational support
  • Otherwise with consent
  • Service providers
  • Advisors and agents
  • Government entities including regulators and law enforcement.
  • Affiliates and subsidiaries
  • Others as required by law

Exercising your rights

If you are a resident of a U.S. state (including California) that grants individuals certain privacy rights (i.e., to know, access, correct, delete, or opt out of ‘sales’ and ‘sharing’ of Personal Data), you may exercise your rights by clicking here or submitting an email to privacy@solventum.com as described above, under “Your Rights.

In addition, we offer other ways for California residents to opt out of ‘sales’ and ‘sharing’ of their Personal Data. Our [U.S. Internet Site] [Websites] respond[s] to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will, subject to applicable law, process that as a request to opt that particular browser and device out of sales and sharing on our [Websites]. Certain residents may also opt out of any cookie and pixel-related ‘sales’ and ‘sharing’ or targeted advertising on any of our [Websites] by adjusting your cookie privacy preferences for that [Website], in our cookie preference manager, which you can access by clicking the “Your Privacy Preferences” link, accessible in the footer of our [Websites]. Note that if you come back to our [Websites] from a different device or use a different browser on the same device, you will need to enable GPC or set your cookie preferences for each browser and device you use to access our [Websites] and services. More information about GPC is available at: https://globalprivacycontrol.org/.

Further information for persons whose data is processed in Switzerland, UK or the European Economic Area

This supplemental notice is for users in the European Economic Area, United Kingdom, and Switzerland and should be read in conjunction with our Global Website Privacy Statement, which includes additional important information for users in these jurisdictions.

 

Data controller and contact information

The controller for Personal Data collected under this Statement is the relevant Solventum entity in your country, and, as applicable, Solventum Company, Compliance and Business Conduct, Solventum Center, Bldg. 220-11W-02, St. Paul, MN 55144-1000. For a list of Solventum data controllers and contact details by country, please click here.

You can reach you can reach Solventum’s Data Protection Office at privacy@solventum.com

If you are using Solventum B2B Services administered by a company (e.g., a healthcare provider), that company may be the controller for Personal Data collected by those Solventum B2B Services, and Solventum will be a ‘data processor’ only. In those scenarios, that company will be the controller responsible for the collection and use of your Personal Data, and for fulfilling your rights as a data subject. Please contact your company for more information.

 

Solventum’s lawful basis for processing your Personal Data

The lawful basis for Solventum’s processing of your Personal Data will depend on the purposes of the processing.

We use the Personal Data we collect as necessary for the performance of a contract. This includes:

  • Establishing your online account;
  • Validating your access to our Services;
  • Processing your online purchase orders;
  • Registering you as the user of, providing you with the functionality associated with, a consumer product;
  • Sharing Personal Data within the Solventum group, as well as with service providers and other third parties;
  • Providing customer service; and
  • Sending you administrative or transactional communications.

We also use the Personal Data we collect when we have legitimate interests in doing so, as long as our legitimate interests are compatible with your rights and expectations of privacy. This includes in:

Purpose for processingLegitimate interest
Responding to requests, queries and/or complaintsOur legitimate interest in providing a customer service function
Operating the Website, including the use of essential cookiesOur legitimate interest in providing a secure and functional website
Performing Website analyticsOur legitimate interest in understanding how our Website is used so we can make improvements to it (except where the analytics rely on cookies or similar technologies for which we are required to obtain your consent)
Conducting customer researchOur legitimate interest in understanding how our products and services are received and used so we can make improvements to them
Analyzing customer service interactionsOur legitimate interest in providing and improving a customer service function
Conducting clinical trialsOur legitimate interest in performing scientific research in order to develop new products that are safe to market
Creating customer profiles based on your use of our products and services, your interactions with us and our platforms, and your expressed interestsOur legitimate interest in understanding our customer base so we can better target our products and services to them
Contacting customers, vendors, suppliers and their respective individual representatives in the ordinary course of businessOur legitimate interest in being able to contact these entities and their represenatives in order to manage commercial relationships and deliver our products and services
Sending your direct marketing communications concerning new or different products or services that might be of interest to youOur legitimate interest in being able to promote our products and services (except where this requires consent under applicable law) 
Investigating, establishing and taking action in respect of potentially unlawful conduct or conduct in breach of contractOur legitimate interest in exercising, establishing and defending our legal rights
Considering or taking steps to enter into a reorganization, restructuring, merger, acquisition or transfer of assets, or other business transactionOur legitimate interest in being free to dispose of our restructure our business or assets

We may use your Personal Data as needed to comply with legal obligations, including:

  • Providing your Personal Data to law enforcement agencies and other governmental bodies when required by applicable laws;
  • Retaining business records required to be retained by applicable laws;
  • Registering and reporting adverse events and other health and safety incidents;
  • Enforcing our rights and those of others; and
  • Fraud prevention.

Finally, we may use Personal Data collected as described in this Statement with your "opt-in" consent where required by law. If you no longer want us to use your Personal Data, for example, to process Personal Data collected through the use of non-essential cookies or similar technologies, or to send you newsletters or directly market our Services, you can opt out at any time by following the instructions in any communication you receive from us. If you opt out, it will not affect the lawfulness of our processing based on your consent before your withdrawal.

 

Solventum’s lawful basis for processing your sensitive personal data

Sensitive Personal Data (also known as "Special Categories of Personal Data") is information related to your race or ethnic origin, political opinions, religion or other beliefs, health, genetic or biometric data, sex life or sexual orientation, criminal background, or trade union membership.

Solventum only processes Sensitive Personal Data:

  • With your explicit consent;
  • To protect your vital interests or those of another person;
  • Where the processing is necessary for purposes of preventive or occupational medicine, the provision of health or social care or treatment, or the management of health or social care systems and services on the basis of relevant country law or pursuant to contract with a health professional;
  • For the establishment, exercise, or defense of legal claims; or
  • To the extent permitted or required by applicable law.

You are not generally required to provide us with any Sensitive Personal Data when using our Website. If your Sensitive Personal Data is required, we will inform you at the time of collection and let you know whether your decision would prevent you from using our Website or the requested Service.

 

International transfers of your personal data

For information about the transfer and storage of your Personal Data outside of the European Economic Area, the United Kingdom or Switzerland, please see above, under “Cross-Border Transfers”. You may request more information regarding our international data transfer mechanisms, and exercise your right to obtain a copy of those mechanisms, by contacting us at the details set forth in this Statement.

 

Exercising your individual rights

As discussed above, under “Your Rights”, you have certain rights with respect to your Personal Data which you can exercise by completing this request form. We will respond to your request in accordance with applicable law. With respect to your right to complain to your local data protection supervisory authority:

in the EU, a list of authorities and their contact details can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en

o in the UK, the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/

o in Switzerland, the Federal Data Protection Commissioner: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html

If you are located in France, you also have the right to set out instructions (general or specific) about what happens to your Personal Data after your death.

Supplemental information for residents of the People’s Republic of China

In this section, we provide additional information to residents in the People's Republic of China (for the avoidance of doubt, excluding Hong Kong SAR, Macau SAR and Taiwan for the purposes of this Statement) (“PRC”) about your privacy rights under applicable privacy laws, including but not limited to the Personal Information Protection Law, the Cybersecurity Law and the Data Security Law of the People's Republic of China.

 

Information collection

We will indicate whether it is mandatory or voluntary for you to provide certain types of Personal Data. However, the collection of some Personal Data is mandatory for the purposes described in this Statement. If you do not provide us such Personal Data, or if you withdraw or restrict the scope of consent (where applicable) for our processing, we may not be able to administer and manage our relationship with you (such as communicate with you or perform our contract with you), which in some cases may mean we are unable to continue with your engagement with us if applicable, or we may be prevented from complying with our legal obligations. In addition, we will rely on an appropriate lawful basis for processing your Personal Data under applicable PRC law.

 

Sensitive personal data

Under the PRC law, sensitive Personal Data refers to Personal Data that, once leaked or illegally used, will easily lead to infringement of human dignity or harm to the personal or property safety of a natural person, including (but not limited to): biometric identification, religious belief, specific social status, medical health information, financial accounts, tracking/location information, and the Personal Data of minors under the age of 14. Providing us with your sensitive Personal Data increases the risk that you may suffer harm to your personal safety or dignity or your reputation, or loss or damage to your property if your sensitive Personal Data is accessed, used, or divulged without authorization while it is in our custody. We will take enhanced security measures to protect your sensitive Personal Data.

 

Disclosure of personal data

You may contact us at privacy@solventum.com to learn more about the separate data controllers to whom we disclose your Personal Data: names, contact information, types of Personal Data shared and the purposes of sharing.

 

Cross-border data transfers

If you are resident in the PRC, with your separate consent, we may share, transfer or store your Personal Data outside of the PRC by applying appropriate data security safeguards to protect the integrity and confidentiality of your Personal Data in accordance with applicable privacy and data protection laws, regulations and industry standards.

Also, to provide you with the requested access to our Websites and Apps, service or supply of Solventum’s products or solutions, we may share your Personal Data with Solventum’s affiliates and other authorized third parties. To learn more about these Solventum affiliates and authorized third parties, and the types of data processing activities that they perform, click here [link].

 

Exercising your rights

Subject to any restrictions and exemptions under applicable law, you may have the rights described above under “Your Rights” in respect of your Personal Data (and in some circumstances, for a deceased immediate family member). As discussed in more detail under “Your Rights”, these rights may include the right to lodge a complaint with us or the Cyberspace Administration of China or the relevant supervisory authority.

If you wish to exercise your rights, you can contact us at the details set out below in the “Data controller and contact information” section. Please note, in some cases, we may request additional information in order to verify your request or where necessary to process your request. We will respond to your request consistent with applicable law.

 

Data controller and contact information

  • The controller of Personal Data for residents of the People’s Republic of China under this Statement is:
    • 3M Healthcare Investments Co., Ltd.
    • 3M Healthcare (Shanghai) Co., Ltd.
    • 3M Healthcare (Guangzhou) Co., Ltd.
    • 3M Medical Devices and Materials Manufacturing (Shanghai) Co., Ltd.
    • KCI Medical China Co., Ltd.
  • If you are using our B2B Services administered by your company, your company may be the controller of Personal Data collected by those B2B Services. Please contact your company for more information.
  • You can reach our PRC Data Protection Officer at: Attn. PRC Data Protection Officer, [38/F Maxdo Centre, No 8 Xing Yi Road, 200336 Shanghai, China], e-mail: privacy_chn@solventum.com.

You can find the contact details of the relevant Solventum legal entity in your country in the Solventum Help Center.

Applicant and Contractor privacy notices

On our website, you will also find other privacy notices that contain important information about your personal data. Please select the privacy notice relevant to you from those below.