Effective Date: June 26, 2020
Last Updated: June 26, 2020
- Information We Collect and the Sources from Which We Collect It
- How We Use Your Information
- Disclosure of Your Information
- Storing Your Personal Information
- Compliance with Local Laws
- Data Security
- Google Analytics
- Opting Out of Cookies
- Links to Third Party Sites
- Do Not Track
- Contact Us
- Your California Privacy Rights
If you are a California resident, please click here for more information about your specific privacy rights.
2. Information We Collect and the Sources from Which We Collect It
It is very important to us that you understand what personal information we collect about you, how we collect it, and why it’s necessary.
We collect information from and about users of the Abound Service (“Members”) from the following sources:
- Directly from you when you provide it to us.
- Automatically When You Use the Abound Service via Internet Service Providers, Operating Systems and Platforms, Browsers, and Similar Technologies.
- Social Media and Publicly Made Statements.
- Through Analytics Tracking Technologies.
- From Third Parties.
Information You Provide To Us
Account Registration & Use of Abound Service: When you sign up for the Abound Service, we collect certain personal information to enable you to sign up for and use the Abound Service. We may also record calls between you and your Abound Guide, for safety purposes and to ensure our teams are delivering a level of service that meets our internal standards. We will always ask for your permission before proceeding with the call.
In order to provide you with personalized services that are tailored to your needs, the Abound Service, including the App, can be used to capture information about your diabetes management, condition of health and your blood glucose meter, including your diabetes type, self-reported medication usage and medical history, food consumption, activity and sleep levels, chat history with an Abound Guide, responses to questions and self-reflection prompts, your hospital address and hospital attendance dates, health care practitioner reports, blood glucose readings, A1c data, and blood glucose meter model number, serial number, and settings.
Voluntary Mobile Device Data: You may choose to give us permission to access certain system services on your device, such as camera and photos, to allow us to provide you with features/functionality that will enhance your Abound Service experience. We will not access these features/functionality without first obtaining your consent. You can manage the App’s access to these system services in your mobile device and/or the App’s settings.
Communications Regarding Abound Services: If you contact us about the App or your account, or for any other reason relating to customer services, or if you complete an online registration or web form, where you contact us with an inquiry or request and similar situations in which you have chosen to provide the information to us, we will process the information to respond to your request, including for customer services support, and we will keep a record of that contact.
Products You Request: Where you request and/or order a product from us, we will collect your personal information in order to process your request.
Automatic Information Collection
Device Information: When you use the Website or App, or if you sync your device with the App, we will automatically receive technical information, including the type of device you use, a unique device identifier (such as your device IMEI number, MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system and software version number, IP address, cookie IDs, the type of mobile browser you use, the country and language code and time zone setting. We will also collect information about your use of the Website or App, such as any errors, log files and administration data so that we can ensure good operation of the Abound Service.
Social Media and Publicly Made Statements
If you engage on social medial platforms regarding the Abound Service, whether in a public or private fashion, or provide comments in a public forum regarding the Abound Service, (e.g., a review in an app store,) we may collect information relating to the nature, content, and sentiment of your communication, the specific social media used, any response we provide to your communication, the date, time, and location of your interaction, and other information related to any interaction between Ascensia and you and/or the content of your communication.
Analytics Tracking Technologies
We use analytics services to help us analyze how you use the Abound Service, including tracking when you are using the Abound Service, how long you use the Abound Service, and your interactions with the various features. The information generated is used to improve the Abound Service and improve your experience with the Abound Service.
From Third Parties
We may receive personal information about you from third parties, including partners we work with in order to provide you with the Abound Service, your employer, health care provider, health care insurance provider, and third party applications that are authorized to send your personal information to us. Our distributors may also share with us personal information that you provide to them when you buy an Ascensia product or otherwise contact them following a purchase. In the event your consent is legally required, we will obtain it from you or will only obtain your personal information from third parties who have obtained it.
3. How We Use Your Information
We process your personal information, including health-related information, to:
- provide you with the Abound Service, and any other information, products or services that you request from us;
- give you notices about your account;
- allow you to participate in interactive features of the Website, tools, software, and the App, when you choose to do so;
- respond to any request we may receive from you, such as requests for App or customer support;
- continue to develop, test and improve the Website, App, and other elements of the Abound Service, including to offer new functionality, products, services, and features;
- better understand how you interact with the Website, App, and other elements of the Abound Service, including its functionality and features, as well as ensure that content is presented in the most effective manner;
- support, maintain and troubleshoot, or fix any issues with the Abound Service;
- evaluate Ascensia product performance and safety;
- communicate with you via notifications, emails, reminders or alerts to inform you of new developments in the App, based on your notifications settings that you can manage on your device;
- conduct data analysis, testing and research, including for statistical purposes and for publishing articles in medical and/or peer-reviewed publications and journals. When used for this purpose, your personal information will be aggregated, anonymised or de-identified/pseudonymised in a form that does not identify you individually and cannot reasonably be used to identify you;
- develop and implement security tools and mechanisms as part of our efforts to keep the Abound Service safe and secure;
- invite you to participate in surveys or opinion groups or other promotional and marketing activities related to the operation and your use of the App, your account or concerning our products and services, including in conjunction with selected third parties;
- where it is in accordance with your marketing preferences, to contact you in the future for our marketing purposes to inform you about our products and services we believe might be of interest to you;
- measure and understand the effectiveness of advertising we may serve and to deliver relevant advertising;
- carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
- notify you when updates are available to the App, Website, and other elements of the Abound Service, and of changes to any products or services we offer or provide though the Abound Service;
- report events to governmental or regulatory authorities that are responsible for medical devices and/or telemedicine policies, including related to medical device reimbursement and funding;
- fulfil a legal obligation;
- as necessary if we need to issue a safety notice or corrective action related to the Abound Service, including the Website, App, our blood glucose meters, or your account; and
- for any other purpose not reasonably related to those listed above with your consent.
We use information that does not directly or indirectly reveal your identify in the aggregate (“Aggregate Data”) for our business purposes. Aggregated Data may be derived from your personal data, but it is not considered personal data.
4. Disclosure of Your Information
We may disclose or receive Aggregated Data for development, marketing, promotional, and other purposes.
In addition, we may disclose your personal information in the following ways:
- Service Providers. We may share your information with our service providers involved in the hosting, development, analytics, troubleshooting or fixes relating to support, testing and maintenance of the Abound Service. Ascensia Service Providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- Ascensia Partners. We may share your information with our selected partners where you have chosen to participate in surveys, opinion groups or other marketing-related initiatives relating to your use of the Abound Service, including, but not limited to, the App or your account, or otherwise to facilitate marketing and advertising.
- Purchasers of our Business. We may share your information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ascensia's assets, in which personal information held by Ascensia about our Members is among the assets transferred.
- With Your Consent. We may also disclose your information to other third parties with your permission.
Third Party App Connections
We may offer the ability to integrate your account with third party applications such as Fitbit or Apple HealthKit. If you choose to connect your Abound account to a third party application, we may share your personal information stored in your account, which may include health-related information, and also receive your personal information from the third party application. Your personal information will only be shared with these applications when you direct us to make the connection, but you can also revoke your consent at any time. Whenever we will share your personal information with a third party application that is connected to your App, you will receive a notification before connecting to the third party application to let you know that personal information will be shared / accessible to a third party application prior to Ascensia sharing your personal information, and an indication of what types of personal information will be shared.
With your consent, we may contact you to tell you about products and services that we feel may be of interest to you or that are similar to those that you have already purchased or enquired about. In some cases, we may also ask for your consent to collect, use, or share personal testimonials of satisfied customers about our products and services in addition to other endorsements. This may include posting your testimonial along with your name in Ascensia publications, presentations, brochures, newsletters/bulletins, and websites. You may opt out of receiving our marketing communications at any time by contacting contacting customer service by visiting email@example.com or (888) 890-8577 or by using the unsubscribe link in any of our communications. If you agreed to provide a testimonial, you may revoke your consent at any time by contacting us at firstname.lastname@example.org.
We will continue to contact you for non-marketing related purposes where we need to send you information about the Abound App, your Abound account, or where we need to issue a field corrective or safety notice, or to where we need to send certain information to you under a legal, regulatory, or ethical requirement. We may send information to you via the App notifications, emails, reminders or alerts to inform you of new developments. You can manage push notifications in your mobile device settings.
6. Storing Your Personal Data
7. Compliance with Local Laws
8. Data Security
You are responsible for protecting against unauthorised access to the App and your account. The App uses your mobile number to authenticate you as a Member and protect your account. Any change to your mobile phone number may affect your ability to log in. If you need to change your phone number, contact Ascensia at email@example.com or (888) 890-8577. Ascensia is not responsible for any lost, stolen or compromised passwords or for any access to your account from unauthorised users where caused by you. If you think your account has been compromised, please contact us as soon as you can at firstname.lastname@example.org or (888) 890-8577.
We use the following cookies on our Website:
- Strictly necessary cookies: Required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, to move around the Website and to use its features.
- Analytical/performance cookies: Allowing Ascensia to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies: These recognize you when you return to our Website. This enables us to personalize our content for you, for example, your choice of language or region.
- Targeting cookies: These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Some of these are persistent cookies that may be used if you log on to restricted areas of our Website to remember who you are. Others are session cookies that may be used for identification of a website visit for technical purposes only. Session cookies are stored only temporarily during the browsing sessions and are deleted once the browser is closed.
- to improve our Website security;
- to analyze how you use our Website by tracking specific actions on our Website, such as visits to the various pages of our Website;
- to collect statistical information on how visitors use our Website so that we can make improvements to its usability and to improve content delivery value;
- to optimize our advertising by ensuring we can deliver on other websites advertising to those who visit our Website;
- to allow us to assess the success of our advertising by identifying events (such as registrations, checkouts, etc.) on our Website which happened as a direct result of our advertising; and
- to make sure our advertising on other websites is relevant to you.
10. Google Analytics
We use Google Analytics cookies to collect information and compile reports about how visitors use our Website, and we use this information to help us improve our Website. Google Analytics mainly uses first-party cookies, which are not shared across different websites that you visit. The information that the cookies collect is mostly anonymous and includes the number of visitors to the Website, where those visitors originate from and how many times they have visited the Website. Google has published information in relation to Privacy and safeguarding data.
Google Analytics will collect your IP address, which is a unique code assigned to every computer and device connected to the Internet. IP addresses are usually assigned in geographic blocks and may allow website operators to identify the country, state and city in which the computer or device is based. We may collect either the full or a portion of an IP addresses to help us identify the location of our website visitors. Google Analytics will also collect demographic and interests information, including age and gender, where available in the cookie.
Google Analytics also uses third-party cookies (such as the DoubleClick cookie) on websites where Google Analytics Advertising Features are used, such as Remarketing or AdWords. Our use of Google Analytics’ Remarketing feature allows targeted and relevant advertising to be delivered to you when you browse elsewhere on the internet. This feature can also work cross-device where you have a Google account and you have chosen to enable Google to associate your web browsing history with your account and to use information from your account to personalize advertising you see across the internet. When you’re signed-in to your Google account, Google will use your data together with the analytics data they obtain by the third-party cookies on our Website to serve better advertising on other websites you visit and based on your past browsing habits. In order to support this feature, Google will collect user’s Google-authenticated identifiers.
More information in relation to these advertising cookies can be found at http://www.google.com/intl/en/policies/technologies/ads/. You may opt-out of these features by visiting Google’s Ads Settings.
11. Opting Out of Cookies
You may refuse to accept cookies by altering the settings on your internet browser (for example Internet Explorer, Chrome and Firefox.) Please note that if you choose not to permit cookies some areas of our Website may not function properly or be accessible.
In general, by consulting the help menu item in your internet browser, instructions on how to disable or delete cookies is available. Most browsers are set-up to accept these cookies automatically. In addition, you can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer.
Please note though, that if you delete your cookies:
- We will no longer know that you've opted out of online behavioral advertising, so the banners from our third-party advertisers will reappear when you visit other selected websites.
The Abound Service, including, but not limited to, the App and Website, is not intended for children under 18 years of age. No one under age 18 may provide any personal information in relation to use of the Abound Service. We do not knowingly collect or use any personal information of anyone we know to be under 18 years old without the prior affirmative, verifiable consent of his or her parent/guardian. A parent/guardian has the right, upon request, to view the information provided by their child and/or to require that it be deleted. If we discover that a child has provided us with personal information online through our Website, we will take reasonable steps to delete this data. If you are a parent/guardian with any concerns regarding your child’s personal information in connection with our Website, please contact Ascensia at email@example.com or (888) 890-8577 or by mail Ascensia Diabetes Care US Inc., 5 Wood Hollow Road, Parsippany, NJ, 07054, United States.
13. Links to Third Party Sites
Links to other websites or applications are provided for information only and do not constitute endorsements of those other websites or applications. Ascensia and/or its affiliated companies are not responsible for the content of links or third-party websites or applications and do not make any representation regarding their content or accuracy. Your use of third-party websites or applications is at your own risk.
We may implement applications or “widgets” from third party providers (e.g., Facebook, Twitter, Instagram, etc.) that allow interaction, integration or content sharing with third party services. These widgets or applications may be visible on a page you visit on our Website or may require log-in through the third party provider’s service. The third party providing the widget or integration may offer controls for you to manage your interactions. Any interaction with a third party widget or application typically allows the third party to collect some information about you (whether through cookies, registration information or otherwise). These third parties may even track you when you do not interact with the widget. If you have engaged any of these third party service providers, their respective privacy policies will govern their tracking and collection of information. You should review these third party policies to understand these practices.
14. Do Not Track
We do not collect personal information about your online activities over time and across third-party websites or online services. We also do not allow third parties to collect personal information about your online activities over time and across other websites or online services when you use the App.
Certain browsers may provide individuals with the ability to communicate that they wish not to be tracked while browsing on the Internet. We do not respond to browser “Do Not Track” signals.
16. Contact Us
If you are a California resident who interacts with us outside of a business-to-business transaction, this section applies. Pursuant to the California Consumer Privacy Act of 2018, below is a summary of the personal information we collect from consumers and the categories of third parties with whom we share consumer personal information. Information about the categories of sources from which we collect information and the purposes of collection are described above in Section 2 (Information We Collect and the Sources from Which We Collect It) and Section 3 (How We Use Your Information).
Categories of Personal Information We Collect
Categories of Third Parties to Which We Disclose Personal Information for a Business Purpose
Identifiers such as real name, postal address, country of origin, IP address, email address, account name, date of birth, other similar identifiers.
Personal information protected by Cal. Civ. Code 1798.80(e), such as medical information or health insurance information, including information about your diabetes management, diabetes types, medications, insulin, food consumption and exercise regime, hospital address and hospital attendance dates, health care practitioner reports, blood glucose readings, and A1c data.
|Characteristics of protected classifications under California or Federal Law, such as age and gender.
Commercial information, including products or services purchased, obtained or considered, or other purchasing or consumer history.
Internet or other electronic network activity information, including, but not limited to, status/HTTP status code, operating system and its interface, version of browsing software, device ID, other device information, browsing history, search history and information regarding a consumer’s interaction with an internet website, application or advertisement.
Geolocation data, such as your precise or approximate location derived from information from your mobile device.
Other audio, electronic, visual, thermal, olfactory, or similar information, such as audio recordings of customer service calls.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Your Rights: Subject to certain legal limitations and applicable exceptions, California residents may exercise the following rights via our web form or by calling (888) 890-8577.
- Right to Know. You have the right to request information about the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the purposes for collecting the personal information, and the categories of third parties with whom we have shared your personal information (“Categories Report”). You may also request information about the specific pieces of personal information we have collected about you (“Specific Pieces Report”).
- Right to Delete. You have the right to request that we delete personal information that we have collected from you.
- Right to Opt Out. We do not sell any personal information (including information about minors).
In accordance with applicable law, we will not discriminate against you for exercising these rights.
Verification: In order to exercise your rights, we will need to obtain information to verify your identity. If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth in this section. For a Specific Pieces Report, we will request personal information sufficient to verify your identity to a reasonably high degree of certainty and seek a signed declaration, under penalty of perjury, that you are who you say you are. In most cases, we will seek to match at least three data points to information we already have about you for this verification process. For a Categories Report or a Request to Delete, we will request personal information sufficient to verify your identity to a reasonable degree of certainty. In most cases, we will seek to match at least two data points to information we already have about you for this verification process. In certain circumstances, we may require additional or different data in order to verify your identity.
Authorized Agents: You may use an authorized agent to exercise your rights on your behalf. If you are making any of the requests above through an authorized agent, we will request written authorization from you and will seek to verify your identity as described above or we will accept a legal Power of Attorney under the California Probate Code to the authorized agent. Authorized agents must call us at (888) 890-8577for further instruction about how to submit documentation demonstrating the agent has authority to exercise rights on the requesting consumer’s behalf. At a minimum, we will require evidence of the agent’s identity (via passport or driver’s license submission), proof of registration with the California Secretary of State, and at least one of the following evidencing proof of your legal authority to act on behalf of the individual who is the subject of this request:
- Written authorization signed by the Consumer
- Certified copy of a Power of Attorney granted under Probate Code, or
- Evidence of parental responsibility.
Timing: We will respond to Requests to Delete and Requests to Know within 45 days, unless we need more time in which case we will notify you and may take up to 90 days total to respond to your request.
Additional California Rights: Under California’s “Shine the Light Law”, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the customer personal information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the name and addresses of those businesses with which we shared customer personal information for the immediately prior calendar year. To obtain this information on behalf of Ascensia, please send an email message to firstname.lastname@example.org with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in the response. Please be aware that not all information is covered by the ‘Shine the Light” requirements and only information on covered sharing will be included in our response.