Privacy Policy

SCOPE

 

This Notice describes how we collect, use, protect, and process Personal Data we collect from or about you when you visit websites or use mobile apps operated and controlled by LifeScan, use our OneTouch® brand of products and solutions (including their websites and mobile apps), communicate with us, or otherwise interact with us in your capacity as a consumer. This Notice does not apply to employees or job applicants of LifeScan, or its subsidiaries. LifeScan has a number of websites and brands that it operates, including the OneTouch® brand of products and solutions, and this Notice also applies to information collected by those brands and through those websites and mobile apps. Throughout this Notice, we use the term “Services” to describe our product and services offerings, including our websites, mobile apps, OneTouch® Reveal products, OneTouch® Solutions offerings, and any other products or services offered by us.

This Notice explains how LifeScan may use and disclose information we collect from and about you, as well as your ability to control certain uses of it. By visiting our websites, interacting with us, or providing us with your data, you consent to the collection, use, and disclosure of your Personal Data in accordance with the terms of this Notice. If local laws in your country require that we process your Personal Data in a different way, we will comply with those local laws. Please read this entire Notice before using any of the LifeScan Services.

If your organization has a separate contract or agreement regarding LifeScan’s use and processing of Personal Data, to the extent that agreement conflicts with this Notice, the agreement will apply. However, where this Notice provides additional rights to individuals beyond the rights included in any such agreement, we will also afford individuals with the rights and choices they may have under this Notice.

LEGAL BASIS FOR PROCESSING

 

For each type of processing of your personal data that we carry out, we rely on an appropriate legal basis, which may include:

Your consent: In some cases, we will explicitly ask for your consent to process your personal data, for example, for certain direct marketing communications.

Performance of a contract: When you use our services, we process your personal data to fulfill our contractual obligations to you.

Legal obligations: We may be required to process your data to comply with a legal obligation, such as keeping invoices for tax purposes.

Legitimate interests: In some cases, we process your data to pursue our legitimate interests in a way that could reasonably be expected in the course of running our business and which does not affect your rights and freedoms in a significant way.

DATA MINIMIZATION

 

We undertake the collection of strictly necessary data only, to achieve the aforementioned purposes and do not use them for any other purposes without prior consent.

DATA COLLECTION METHOD

 

We undertake the collection of strictly necessary data only, to achieve the aforementioned purposes and do not use them for any other purposes without prior consent.

NATURE OF PERSONAL DATA COLLECTED

 

The term “Personal Data” in this Notice means any information which could identify you as an individual, either directly (for example, your name) or indirectly (such as an IP address or other unique identifier), or any information that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

LifeScan may collect and process the following categories and types of Personal Data when you use the Services:

• Identifiers, such as your name, contact information, address, telephone number, online identifiers, and demographic information such as date of birth and gender.
• Protected classification characteristics under state or federal law, such as age, ancestry, and medical condition.
• Commercial information, such as records of products or services purchased, billing details, and information about previous transactions.
• Medical, health, and biometric information, such as blood glucose readings, exercise and carbohydrate intake, and diabetes type and method of management.
• Internet or other similar network activity, such as information about your interactions with our Services or advertisements.
• Geolocation data, such as the physical location of you or your device that accesses our Services.
• Audio, electronic and visual information, including photographs, videos, if you provide a testimonial or voice recordings, if you interact with our customer service or provide a testimonial.
• Professional information and education information, such as information about your medical specialty if you are a healthcare provider.
• Inferences we derive from the information that we collect, to create profiles reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Information categories listed in state statutes, including the information protected by California Civil Code Section 1798.80, subdivision (e), such as name, contact information, financial information, and health insurance information.
• Sensitive Personal Data or Special Category Personal Data, such as the health information listed above, and information about your racial or ethnic origin.
• Social media profile information, when you share it with us or use it to contact us.
• Account-related information, such as the password you select to use the Services or the serial number of any devices associated with the account.
• Device information and unique device identifiers, such as your IP address, operating system, or the serial number of your device.
• Complaint or adverse event information.
• Preference information, including your communication, language and time zone preferences.
• Any other Personal Data you choose to provide to us.
• Any other Personal Data you consent to the collection of at the time of collection.

When you are asked to provide your Personal Data, you may have an option to choose not to provide it. While this is your choice, if you do not provide it, it may inhibit our ability to provide some elements of the Services to you.

If you are providing information of someone other than yourself (for example, if you are a caregiver, parent or guardian or a healthcare professional providing a patient’s information) then you are confirming to us that you have any legally required authorization, consent or other lawful authority to share the other person’s information and for us to use it in accordance with this Notice.

In addition to the above information, if you are a healthcare professional, LifeScan may collect:

• Your professional qualifications, educational and professional history, professional and government affiliations, information included on a resume, languages spoken, information about publications with which you have been involved;
• Information about the LifeScan programs, products and activities with which you have engaged;
• Details about our interactions with you, your prescribing of our products and any agreements you have or had with LifeScan, including payment or other financial details;
• Information collected in connection with LifeScan events, training or activities you have attended or with which you have been involved; and
• Public information such as license information and other due diligence related information.

Non-Personal Data

We may collect and use information that is not personally identifiable, such as information that is aggregated, de-identified, or otherwise not personal in nature. We may also take Personal Data we have collected and de-identify it or compile it so that it is aggregated and no longer personally identifiable in nature.

MANDATORY OR OPTIONAL NATURE OF DATA COLLECTION

 

When you are asked to provide your Personal Data, you may, as an exception, choose not to provide them. It is important to note that certain data is essential to enable us to provide you with our Services. If you choose not to provide this mandatory data, it may limit our ability to offer you some of our Services.

PURPOSE OF DATA PROCESSING

 

The data collected is used to provide and improve our services, to communicate with users, to personalize the user experience and to comply with our legal obligations.

HOW LIFESCAN COLLECTS PERSONAL DATA

 

The information we collect from or about you and how we use it depends on your interaction with us. For example, we collect different information from you when you use our Services, contact us for information, visit our websites or use our mobile apps.

Information Directly Collected

LifeScan collects Personal Data directly from you or that you provide to us in a number of ways, including:

• From you or your authorized representative, for example, when you sign up for an account for one of the Services.
• When you use one of our Services.
• When you share your social media profile with LifeScan or use it to contact us.
• When you respond to LifeScan surveys or promotions, where permitted.
• When you contact LifeScan for customer service assistance.
• When you share complaints or adverse event information with LifeScan.
• If you are a healthcare professional, if you engage with one of our sales representatives, attend an online or live event such as a conference, training or advisory board meeting.

Information Automatically Collected

LifeScan collects Personal Data automatically, including:

• Indirectly through tracking technologies, including over time and across third-party websites and online services. You can read more about this here. We may also automatically collect information about you from website interaction, analytics partners, and other parties.

Information from Third Parties and Other Sources

LifeScan collects Personal Data from third parties and other sources, including:

• When you authorize third parties to provide your information to us.
• From other products, services or applications that are integrated with our Services (such as, for example, when a third party product, service or application is linked with our Services or vice versa, as applicable, including Google Health Connect, and Apple Health).
  • The use of information we collect from Google Health Connect will adhere to the Health Connect Permissions policy, including the Limited Use requirements.
• From publicly available or third party information sources.
• From third party service providers or our business partners.
• From social media, for example mentioning a LifeScan product or service in a post.

Combining Information

We may combine Personal Data we collect from or about you with Personal Data or information we collect from other sources, for example social media or from public sources.

HOW LIFESCAN USES PERSONAL DATA

 

Our legal basis for processing your Personal Data depends on the reason for which we are processing it. Our legal bases for processing your Personal Data generally include processing with your consent, to perform our contractual obligations to you and to provide you with the Services you request from us, to comply with our legal obligations, and processing that is necessary in our legitimate interests.

We process your health information when you use the Services on the basis of your explicit consent.

We use your Personal Data for the following purposes where it is necessary for us to perform our contractual obligations to you and to provide you with the Services you request from us:

• Manage your account on our Services.
• Provide our products or the Services to you.
• Respond to your enquiries and fulfill your requests, such as to send you documents you request.
• Provide customer service support to you.
• Send you important information regarding our relationship with you or the Services, or regarding changes to the Services, our terms of use and other policies or administrative information, such as planned maintenance or downtime.

We use your Personal Data for the purposes listed below where it is necessary or in our legitimate interests, unless you have opted-in to receive communications where an opt-in is required by law (as applicable to the purposes listed below). If you have opted-in to receive such communications, our additional legal basis for processing your Personal Data for this purpose is your consent.

• Operate our business.
• Improve, enhance, and develop our products and Services.
• Perform our contractual obligations with other entities, organizations, and third parties.
• Market our products and services to you.
• Invite you to participate in surveys and promotions, and to provide feedback on our products and/or services.
• Identify trends regarding our Services and use of the Services.
• Personalize your experience when you interact with us.
• Undertake market research, analytics or segmentation so that we can better understand your needs and so that we can improve our products and services.
• Understand the effectiveness of our marketing campaigns and to tailor our communications with you.
• In connection with our cybersecurity efforts.
• Ensure continuity of service to you if we sell, assign or transfer part of our business or enter into a relationship with a distributor.
• Provide you with information about our products and services or the products and services of selected third-party partners.

We use your Personal Data for the following purposes in order to comply with a legal obligation that we are subject to, or where necessary to establish, exercise or defend legal claims:

• Comply with legal or regulatory obligations to which LifeScan is subject, such as reporting complaints or adverse events, anti-corruption, or in connection with trade compliance and transparency reporting requirements for healthcare professionals.
• Comply with subpoenas, regulatory inquiries and other lawful judicial process.
• To defend LifeScan against actual, potential or threatened litigation.

We may also use your Personal Data in other ways, with your consent.

DE-IDENTIFIED, ANONYMIZED, AND AGGREGATED DATA

 

We may permanently anonymize or de-identify your Personal Data so that it is no longer Personal Data under relevant laws. After permanent anonymization or de-identification, you can never be identified and the data is not traceable to you, and we will not take steps to re-identify the data so that it is identifiable. We may use or share such anonymized or de-identified data for statistical analysis, clinical research, product development or improvement, demographic analysis or other similar activities. The legal basis for such data processing is our legitimate interest. We may export and process permanently anonymized data in any country in which we or one of our service providers or business partners has operations. We may combine or aggregate anonymized or de-identified data with other third-party data that we collect.

HOW LIFESCAN DISCLOSES PERSONAL DATA

 

We may disclose any or all categories of Personal Data that we collect from or about you when you use the Services or otherwise interact with us with any of the following categories of third parties:

• LifeScan’s affiliates and subsidiaries for the purposes described in this Notice.
• Our third-party service providers, vendors, and consultants who provide services to you or us, such as order fulfillment, website hosting and moderating, mobile application hosting, data analysis, payment processing, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, credit card processing, auditing services, and other services, in order to enable them to provide services to you or us.
• Your authorized health care provider (such as a clinic, pharmacy or healthcare professional), payor or to other third parties that you choose to provide access to your Personal Data. Some of our Services permit you to share all of the information you enter within the particular Service or to share certain information with a relative, friend or caregiver.
• Third party partners with whom we offer a co-branded or co- marketed promotion , when you provide consent for us to do.
• Business partners or third parties where you choose to integrate their products or services with the Services (such as, for example, when you link our Services with a partner’s product, application or service (or vice versa)).
• Successors in interest and third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
• Advertising and analytics third-party service providers who provide these services to us.
• Other third parties for our business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our products and services, identifying usage trends, where permitted, personalizing your experience by presenting products and offers tailored to you, and determining the effectiveness of our promotional campaigns.
• Any other third party that you consent to, as you otherwise direct us to, or as otherwise described to you at the time your information is collected.

In addition, we may use and disclose information collected through our Services as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence;(d) to enforce our terms and conditions; (e) to protect the operations of LifeScan group companies; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER PRODUCTS, SERVICES AND APPS

 

The Services may include functionality that links to or integrations with the products, services, websites or apps of our business partners (“Partner Apps”). In the event that you use Services that include such functionality, our business partners’ privacy policies, notices, or statements will govern how they handle your Personal Data in connection with such Partner Apps, while this Notice will continue to govern how we handle your Personal Data. We are not responsible for our business partners’ privacy practices, and you should review the applicable Partner App privacy policies before using such functionality.

EMAIL COMMUNICATIONS

 

We may send you email messages promoting our Services or other information about our programs and offers; and, where required by law, when we have the appropriate consent to do so. You may opt out of receiving marketing and promotional communications at any time by contacting us, using the unsubscribe link in the applicable communication, or by changing your preferences in the “My Account” or “Settings” function, if applicable. If you opt-out of receiving marketing and promotional communications from us, you may continue to receive legal notices, non-marketing product updates (such as, updates to our terms of service or use that govern the product), and other transaction-related messages from us.

If you are a healthcare professional and no longer wish to receive communications from the LifeScan Diabetes Institute, you can update your preferences in your member profile at www.lifescandiabetesinstitute.com or by unsubscribing, here.

COOKIES, INTEREST-BASED ADVERTISING AND OTHER TOOLS

 

We use persistent identifiers such as cookies, clear GIFs, pixel tags, web beacons, and similar technologies to automatically collect data from you when you use our Services. These persistent identifiers collect information that allows us to authenticate you to the Services, to analyze how the Services are used, to link information about how you use the Services with your account, to analyze the effectiveness of our messaging, and to help to tailor our products, the Services, and our communications to you. We may also use persistent identifiers to identify you across other media, websites, or apps, or through your use of our other products or the Services to help to tailor our offerings and to provide enhanced personalization and communications. When we use the term “cookies,” we intend for this to encompass cookies, clear GIFs, pixel tags, web beacons, and similar technologies. For more information about how we use cookies to automatically collect information from you and how you can manage your preferences or exercise rights you may have regarding information collection through cookies, please review our Cookie Policy.

Cookie Preferences and Choices

We appreciate that you may wish to express certain preferences with respect to some or all categories of cookies used to collect information, including Personal Data, from you, through our websites and applications. You may express your preferences regarding our collection of information via cookies through:

• Our cookie consent tool located on our websites. The cookie consent tool can be accessed the first time you visit our website, or if you clear your browser cache or access the browser in private browsing mode. Specifically, the Cookie Consent Tool permits you to control the non-essential cookies set when using our websites. Please note, the required or essential cookies cannot be managed, nor can the Cookie Consent Tool be used to block cookies on third-party websites linked from our websites.
• Your browser settings. The browsers of most computers, smartphones, and other web-enabled devices are typically set up to accept cookies. If you wish to amend your cookie preferences for any website, you can do this through your browser settings. Your browser’s “help” function will tell you how to do this. However, please remember that cookies are often used to enable and improve certain functions on our websites. If you choose to switch certain cookies off, it is likely to affect how a particular website works. To find out how to manage cookies on popular browsers, you can visit www.allaboutcookies.org.
• By providing your preferences to third parties.
  • You can learn about Google’s practices by going to: https://www.google.com/policies/privacy/partners. To the extent available from Google, you can opt out of Google Analytics by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • You can read more about Hotjar’s privacy practices at: https://www.hotjar.com/privacy. To the extent available from HotJar, you can opt-out of HotJar’s use of their tracking cookie at: https://www.hotjar.com/policies/do-not-track/.
  • You can read more about AppsFlyer’s data processing at: https://www.appsflyer.com/privacy-policy/. To the extent available, if you wish to opt-out please go to: https://www.appsflyer.com/optout.

SALE OR SHARING OF PERSONAL DATA

 

LifeScan does not sell Personal Data for money, but in the last 12 months we have shared Personal Data including identifiers, commercial information, online identifiers and internet or similar network activity details, with providers of advertising and analytics services, network advertisers, partners who assist us with target audience creation, retail partners, and brands of our parent company. This sharing and disclosure may be considered a “sale” or “sharing” under applicable state law.

YOUR PRIVACY RIGHTS AND CHOICES

 

If you would like to update or correct your Personal Data, you may do so by updating your information in the “My Account” or “Settings” feature of the Services.

In addition to the foregoing, depending on the jurisdiction in which you reside, you may have the following additional rights and choices regarding your Personal Data. While we use the term Personal Data throughout this Notice, we intend for this to include “personal information” where that is the term used under applicable law. If you have questions about whether you live in a jurisdiction that affords privacy rights, please contact us using one of the methods listed below.

Right to Request Access or Right to Know

Where required under applicable law, you have the right to request that we disclose information to you about our collection and use of your Personal Data over the past 12 months. You have the right to request the following:

• The categories of Personal Data we collected about you.
• The specific pieces of Personal Data we collected about you.
• The categories of sources for the Personal Data we collected about you.
• The business or commercial purpose for collecting your Personal Data.
• The categories of third parties with whom we have disclosed your Personal Data in the preceding twelve (12) months.
• The categories of Personal Data we sold or shared about you, and the categories of third parties to whom the Personal Data was sold or shared by category of Personal Data.

Once we receive and confirm your verifiable consumer request, we will provide you with the information you request unless an applicable exception applies.

Right to Portability

Where required by applicable law, after you make a request to access or know your Personal Data you may have the right to request to obtain a copy of this information in a portable, readily usable format that allows you to transmit the information to another party, to the extent it is technically feasible. You may also have the right to request that we transfer your data to another organization, under certain circumstances.

Right to Deletion or Right to Erasure

You have the right to request that we delete any of the Personal Data that we collect or retain about you, subject to certain exceptions. After we receive and verify your request, we will delete (and direct any of our service providers that hold your Personal Data on our behalf to delete) your Personal Data from our records, unless an exception applies. We may deny your deletion request if retaining your Personal Data is necessary for us or our service providers, as permitted by law.

Right to Opt-Out of the Sale or Sharing of Personal Data, or the Use of Personal Data for Targeted Advertising

You have the right to opt-out of the sale or sharing of your Personal Data. Information about our practices that may constitute a “sale” or “sharing” of your Personal Data as defined by law are noted in the above section titled “Sales or Sharing of Personal Data.” You may exercise your right to opt-out by following the instructions set forth in this section of this Notice titled “Exercising Your Rights,” or by utilizing the “Do Not Sell or Share My Personal Data” button on our website. Please note you may also need to update your preferences in the cookie consent tool on our websites and apps in order to fully opt-out.

n some states, this right is known as the right to opt-out of the use of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of certain decisions.

Right to Limit Certain Uses and Disclosures of your “Sensitive Personal Data”

You have the right to limit our use and disclosure of your “Sensitive Personal Data,” as that term is defined in applicable statutes, where we have collected it to use as necessary to perform the services or provide the goods reasonably expected by you, and as otherwise authorized by the statute and regulations. We use your Sensitive Personal Data in ways that you would reasonably expect are necessary to perform the services or to provide you with the Services you request. We may also use your Sensitive Personal Data for our legitimate business purposes, including for marketing to you. For details on how we use your Sensitive Personal Data, and your right to opt-out of certain uses, please review the information above.

Right to Correct Personal Data if the Data is Inaccurate

If you believe or discover that Personal Data we have collected about you is inaccurate, you may contact us to request that we correct and update the information so that it is accurate. Where applicable, you may also log into the “My Account” or “Settings” page of the Services to update your information.

Right to Withdraw Consent

If you have previously consented to the use of your Personal Data for direct marketing or targeted marketing, you may withdraw your consent at any time.

Right to Restrict or Object to Processing

You may have the right to restrict certain processing of your Personal Data, or to object to certain processing of your Personal Data, including where our legal basis for the processing is your consent, where the processing involves Special Category Personal Data or Sensitive Personal Data, or where it involves automated decision making technologies. This right is subject to certain restrictions.

Right to Appeal

If you are a resident of certain jurisdictions, you have the right to file an appeal with us if we deny your request to exercise your rights. Requests to appeal can be communicated through the same means by which your request was submitted. If we deny your appeal, you may have the right to appeal to your state regulator. We will provide you the information of the applicable regulator if we deny your appeal.

In addition to the above rights, you also have the right to:

• Appoint an individual to exercise your rights on your behalf, or to exercise rights on behalf of your minor child, if we have collected their information.
• Access information about automated decision making (as applicable).
• Opt-out of automated decision making (as applicable).
• To not be discriminated against for exercising your rights.

Right to freeze the use of your data

If you dispute the accuracy of the data used, you can ask us to freeze the use of your data. During this time, we will keep your data but will not use it.

Right to delist content

The right to delist allows you to ask us to remove certain search results associated with your identity, so that you are no longer associated with content that would be prejudicial to you.

Right to Lodge a Complaint

You may have the right to make a complaint with the supervisory authority for your country of residence. If you are an EU Resident, details can be found here.

Exercising your Rights

If you believe you reside in a jurisdiction that affords broad consumer privacy rights to its residents and you wish to exercise any of the rights described above, please submit a request to us by one of the methods noted at the end of this Privacy Policy.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.

Where this right exists under applicable law, you may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will take steps to verify your consumer request, including that you are the person making the request, or you have authority to make the request on behalf of the individual the request relates to. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format: We endeavor to respond to verifiable consumer requests within forty-five (45) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination: We will not discriminate against you for exercising any rights you have under applicable law. Unless permitted by applicable law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by state law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Data’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

HOW LONG WE RETAIN AND HOW WE SECURE YOUR DATA

 

We retain your Personal Data for the period necessary to fulfill the purpose(s) for which it was collected as outlined in this Notice, unless a longer retention period is required or allowed by law or is needed in order to fulfill a legal requirement to which LifeScan is subject.

LifeScan uses various technical, organizational and administrative measures to protect your Personal Data against loss, unauthorized use or access. For example, when we transmit your health-related Personal Data, through our Services we use encryption technology. When our Services communicate with our analytics providers, encryption is also used. However, you should be aware that no data storage or method of transmission can be guaranteed to be 100% secure or error-free.

SAFETY AND OTHER REGULATORY REPORTING

 

n order to ensure the safety of medical devices, regulators place a legal obligation on manufacturers to report certain complaints and potential adverse events to them. LifeScan may share this information with other LifeScan companies in other countries, its service providers or business partners who assist in the maintenance and operation of LifeScan’s complaints database.

In some cases, LifeScan may not be the legal manufacturer of the devices that we promote or make available (continuous glucose monitoring system (“CGM”), for example). In those circumstances, we are obliged to pass on details of complaints and potential adverse events to the device’s legal manufacturer so that they may report the matter to applicable regional or national regulatory bodies, including those that may have different data protection laws than the laws that apply in your country. This means that LifeScan may need to transfer details of complaints and potential adverse events relating to CGM outside the country in which you reside, which may include the United States. Where this occurs, LifeScan takes steps to ensure that your personal data continues to be treated in accordance with applicable data protection laws.

Where relevant, LifeScan enters into European Union standard contractual clauses (or equivalent measures) with the party outside the European Economic Area receiving the personal data. A copy of the relevant standard contractual clauses is available upon request.

LifeScan processes complaint and adverse event data in order to comply with legal requirements to which it or its business partners are subject. Where LifeScan processes health data (which is a special category of data or “sensitive personal information,” as the term is used under the laws of some jurisdictions) for these purposes, LifeScan does so for reasons of public interest in ensuring high standards of quality and safety of medical devices. We may use data provided for complaint and/or adverse event reporting purposes for direct marketing where permitted by law.

f you are a healthcare professional, LifeScan may be required, by law or industry codes of practice, to report on or to make public disclosures of certain payments or transfers of value to healthcare professionals (such as consulting fees, travel and other permitted expenses). Where required by local law, we will disclose your identity, your location and the nature and amount of the transfer of value or payment.

STORAGE SECURITY

 

The data we collect is stored on servers that guarantee a high level of security.

LINKS TO OTHER SITES

 

When we provide a link to another website or application that is not owned or controlled by LifeScan, your data is no longer within the scope of this Notice, and is subject to the information processing practices of that website or application. We may endeavor to provide you with notice when you are leaving our websites to that you are aware that you are leaving our website. However, we are not responsible for how such websites or applications handle your Personal Data. We urge you to read the linked website’s privacy policy, notice, or statement. The inclusion of a link to a third-party website or application does not mean that LifeScan endorses that website or application.

TRANSFERS TO OTHER COUNTRIES

 

As a global company, we have operations and service providers that may not be located in your country of residence. By using any of our Services or, where required by law, by providing us with your consent, your information may be processed and / or stored outside of your country of residence. Data protection laws in those countries may differ from the laws in your country of residence.

For residents of the European Economic Area (“EEA”) some countries outside the EEA are recognized by the European Commission as providing an adequate level of data protection (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we endeavor to ensure that adequate measures are in place, including by ensuring that the recipient is bound by the European Union’s Standard Contractual Clauses or by another method which has been approved by the European Commission, or by an applicable transfer framework approved by UK and/or Swiss regulators, as applicable.

CHILDREN’S PRIVACY

 

We do not collect knowingly information through our websites or mobile apps directly from children under the age of 13. Some of the Services allow the creation of a parent or guardian account which allows for the submission of a child’s Personal Data by a parent or guardian. Please contact us if you believe that a child has provided his or her Personal Data to us directly, without the consent of a parent and take appropriate steps to remove it or obtain consent, as permitted by law.

HOW YOU CAN CONTACT US

 

For privacy-related enquiries or complaints, please contact us as follows:

• By sending an email or writing to our privacy officer at: privacy@lifescan.com
• By calling our customer service team, toll free, at +1 (800) 227-8862

UPDATES TO THIS PRIVACY NOTICE

 

We may update this Notice from time to time. To the extent permitted by applicable law, any changes will be effective when we post the revised Notice on our Services and your continued use of the relevant Service after these changes means that you accept the relevant changes. If the changes are significant, we may provide a more prominent notice to let you know what the changes are (e.g. via our website or by email). This Notice was last updated as of the “Last Updated” date shown at the top of this Notice.