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Gluroo Privacy Policy

Last Updated: October 25, 2021

This “Privacy Policy” shall apply to your access to and use of the Gluroo application, its related applications, cloud-based service, and any other associated websites or services owned and operated by Gluroo (the “Services”) provided to you and your Authorized Users (collectively, “you,” “your,” or “User”) by Gluroo Imaginations, Inc. (“we,” “us,” “our,” or “Gluroo”).  Your use or continued use of the Services constitutes your consent to this Privacy Policy.  Capitalized terms not otherwise defined in this Privacy Policy shall have the meaning provided in the Gluroo End User License Agreement found at https://gluroo.com/eula.html.

This Privacy Policy describes the information we collect from those who access and use the Services.  It also describes how we use that information, and, in some instances, how we share that information.

We use your information to provide and improve the Site and the Services.

By accessing or using the Site or the Services, you agree to the collection and use of your information in accordance with this Privacy Policy.

DEFINITIONS

Cookies” means small data files stored on your device (computer or mobile device).

Data Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information is, or is to be, processed.  For the purpose of this Privacy Policy, we are a Data Controller of your Personal Information collected by us.

Data Processors” means any natural or legal person who processes Personal Information on behalf of the Data Controller.  For purposes of this Privacy Policy, we are a Data Processor for any Personal Information of others collected by you.

Data Subject” (or “User”) means any living individual who is accessing and using the Services, or ordering, purchasing, and using the Services, and is the subject of Personal Information.

Personal Information” means information about a living individual who can be identified from that information (or from that information and other information either in our possession or likely to come into our possession).

Usage Data” means data collected automatically which is either generated by the access and use of the Site or the Services, or from the Site infrastructure itself (for example, the duration of a page visit).

INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes to provide the Site and the Services to you, as well as to constantly improve our offerings in that regard.

Personal Information

While accessing and using the Services, we may automatically collect or ask you to provide us with certain Personal Information that can be used to contact or identify you.  This Personal Information may include, but is not limited to:

          First name and last name

          Credit card information (number, expiration date, CCV code, etc.)

          Work and/or personal contact information, which may include:  telephone number, email address, and physical and/or mailing address

          Physical characteristics, such as height, weight, or other characteristics which may have a bearing on your applicable medical condition

          Information regarding medications, exercise activities, doctor visits, etc. applicable to your medical condition

          Contact information for others who you wish to invite to join your Glucrew

          Cookies

          Usage Data

When you order, purchase, or use the Services, we ask for information such as your name, mailing address, email address, telephone number, credit card information, and other personal identifying information.  Gluroo uses this collected information to fulfill your order, improve our services, contact you regarding your order, contact you regarding promotions, surveys, services and other matters, conduct research, and provide de-identified reporting for internal and external clients.

We may use your Personal Information to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you.  You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us.

Glycemic Event Log

All of your and your Glucrew’s activity in using the Services, including text messages, photographs, diary entries, medicine application, prescription(s) and dosage information, meal records, medical device data, and all other data, information, or content entered by you or your Glucrew, is collected into a Glycemic Event Log (the “GEL”).

Medical Device Data

We collect data from medical devices used in conjunction with the Services.  Specifically, from continuous glucose monitors (“CGM”) and insulin pumps used in conjunction with the Services we collect CGM-reported blood-glucose levels and pump-entered data including food announcements and insulin dosing amounts/changes.

 

Usage Data

We may also collect Usage Data about your access and use of the Services.  This Usage Data may include information such as your device’s Internet Protocol (IP) address, geographical location[MBA1] , operating system, the features of the Services that you access and use, the time and date of your access and use, unique device identifiers, and other diagnostic data.

Tracking Cookies Data

We use Cookies and similar tracking technologies to track the activity on the Site and to hold certain information.  Cookies are sent to your browser or app from a web server and stored on your device.  Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze the Site and our services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.  However, if you do not accept cookies, you may not be able to use some portions of the Services.

Examples of Cookies we may use include, but are not limited to:

          Session Cookies. We use Session Cookies to operate the Site.

          Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

          Security Cookies. We use Security Cookies for security purposes.

USE OF DATA

Gluroo uses the collected information and data described in this Privacy Policy for various purposes:

          To provide and maintain the Services.

          To notify you about changes to the Services.

          To allow you to participate in interactive features of the Services when you choose to do so

          To provide customer and technical support.

          To conduct research into, and develop tools related to, the treatment of diabetes.

          To gather valuable information so that we can analyze and improve our services.

          To monitor the usage of the Services.

          To detect, prevent, and address technical issues.

          To provide you with news, special offers, and general information about other goods, services, and events which are offered by us or our partners that are similar to those that you have already purchased or inquired about, unless you have opted not to receive such information.

          Your Personal Information, especially information regarding physical characteristics, medications, exercise activities, etc., may be used in de-identified and aggregated form (i.e., such that your Personal Information is not linked to you and is not distinguishable from the Personal Information of others in the aggregated sample) either internally, or provided to third parties, for research purposes.

HOW DO WE STORE YOUR DATA?

Gluroo takes reasonable technical and procedural steps to maintain the security and integrity of your personal information.

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are from the European Economic Area (EEA), Gluroo’s legal basis for collecting and using your Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.

Gluroo may collect and process your Personal Information because:

          We need to perform a contract with you.

          You have given us permission to do so.

          The processing is in our legitimate interests and it is not overridden by your rights.

          To comply with the law.

RETENTION OF DATA

Gluroo will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy.  We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Gluroo will also retain Usage Data for internal analysis purposes.  Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer periods.

TRANSFER OF DATA

Your information, including Personal Information, may be transferred to, and maintained on, servers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your home jurisdiction.

If you are located outside of the United States and choose to provide information to us, please note that we may transfer the data, including Personal Information, to the United States and process it there.  The Services and Gluroo’s operations in providing the Services are conducted in the United States.

Your acceptance of and agreement to this Privacy Policy, followed by your submission of Personal Information represents your agreement to such transfers.

Gluroo will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.  No transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Information and other data and information.

DISCLOSURE OF DATA

Business Transaction

If Gluroo is involved in a merger, acquisition, or asset sale, your Personal Information may be transferred to the acquiror.  We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.

Donation/Sale to Third Parties

Gluroo may donate, sell, or otherwise provide data and information from you GEL to third parties, especially third parties involved in projects related to the understanding, diagnosis, and/or treatment of diabetes or other medical conditions, provided such data and information is de-identified and/or aggregated with other data and information such that your data and information is not discernable from the data and information of others.

Disclosure for Law Enforcement

Under certain circumstances, Gluroo may disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements

Gluroo may disclose your Personal Information in the good faith belief that such disclosure is necessary to:

          Comply with a legal obligation.

          Protect and defend the rights or property of Gluroo.

          Prevent or investigate possible wrongdoing in connection with the Services.

          Protect the personal safety of users of the Services or the public.

          Protect against legal liability.

Third-Party Marketing

Gluroo may disclose your Personal Information (specifically, email address), to third parties for their direct marketing purposes, to provide you with news, special offers, and general information about other goods, services, and events which are offered by such third parties, unless you have, if applicable, opted to not have your personal information sold to third parties for their direct marketing purposes.

SECURITY OF DATA

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure.  While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.

YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights.  Gluroo aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.

If you wish to be informed about what Personal Information we hold about you, and if you want it to be removed from our systems, please contact us.

In certain circumstances, you may have the following data protection rights:

          The right to access, update, or delete the Personal Information we have about you.  Whenever made possible, you can access, update, or request deletion of your Personal Information directly within your account settings section in the Services.  If you are unable to perform these actions yourself, please contact us to assist you.

          The right of rectification.  You may have the right to have your information rectified if that information is inaccurate or incomplete.

          The right to object.  Under certain conditions, you may have the right to object to our processing of your Personal Information.

          The right of restriction.  You may have the right to request that we restrict the processing of your Personal Information.

          The right to data portability.  You may have the right to be provided with a copy of the Personal Information we have about you in a structured, machine-readable, and commonly used format.

          The right to withdraw consent.  You may also have the right to withdraw your consent at any time where Gluroo relied on your consent to process your Personal Information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information.  For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

YOUR DATA PRIVACY OBLIGATIONS

To the extent you include the Personal Information of others (for instance, employee names, identification numbers, physical descriptions, descriptions of events/incidents which may tend to identify individuals, etc.) in the content, data, or other information you submit in using the Services (your “User Content and Data”), you are the Data Collector of such Personal Information, and Gluroo is a Data Processor acting at your instruction.  Your instruction to Gluroo is solely to store, sort, and present such Personal Information on demand via the interface provided by the Services.  You are solely responsible for ensuring your collection of such Personal Information is compliant with all applicable laws and regulations, including, but not limited to, the GDPR and CCPA.

SERVICE PROVIDERS

We may employ third-party service providers to facilitate our provision of the Services, to provide the Services on our behalf, perform Service-related services, or assist us in analyzing how the Services, are used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated to not disclose or use it for any other purpose.

SURVEYS

We may conduct user surveys to better target our content to our audience.  Participation in these surveys is completely voluntary, and you therefore have a choice whether or not to disclose such information.  We sometimes share the aggregated demographic information in these surveys with our partners.  We never share Personal Information collected through surveys with such third parties

MARKETING

Gluroo would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop Gluroo from contacting you for marketing purposes or giving your data to Gluroo’s affiliates for marketing purposes.

If you no longer wish to be contacted for marketing purposes, please email marketing.opt.out@gluroo.com with your request.

LINKS TO OTHER SITES AND SERVICES

The Services may contain links to other services or websites that are not operated by us, specifically including, but not necessarily limited to, the ability for you to choose to share your GEL with a NightScout instance (and/or other data storage options which may be available to you).  If you click or use such a third-party link, product, or service, you will be directed to that third party's website, product, or service.  We strongly advise you to review the privacy policy of every third-party website, product, or service you visit or use.  Gluroo is not responsible for any of your Personal Information or User Content and Data that you permit to be accessed by such a third-party website, product, or service.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

MEMBERS OF YOUR GLUCREW

While you are in complete control of who may join and remain in your Glucrew, it is important to note that we are not responsible for the acts or failures to act of your Glucrew members.  Glucrew members will have access to all of the data and information stored and communicated among Glucrew members via the Services, including past data and information.  It is your responsibility to ensure your Glucrew members do not further disclose the data and information collected via the Services.

 

CHILDREN'S PRIVACY

Persons under eighteen (18) years old (“Children” or “Child”) are not permitted to access or use the Services without the permission and active supervision of an adult parent or guardian.

We do not knowingly collect Personal Information from Children under the age of thirteen (13) without express consent of an adult parent or guardian.  If you are a parent or guardian and you are aware that your Child has provided us with Personal Information without your consent, please contact us.  If we become aware that we have collected Personal Information from a Child without verification of parental consent, we will take steps to remove that information from our servers.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on the Site, prior to the change becoming effective and will update the "Last Updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.  Changes to this Privacy Policy are effective when they are posted on this page.  Your continued (or new) access and use of the Site or Services, shall be your acceptance and agreement with this Privacy Policy.

CONTACT US

If you have any questions about this Privacy Policy, please contact us:

By email:  legal@gluroo.com

By mail:  Gluroo Imaginations, Inc.

                      340 S. Lemon Ave. #1703

                      Walnut, CA 91789 USA