[company legal name]
Revised: [revised date]
Thank you for visiting [url], which is hosted and operated by [company legal name] (“[company name],” “we,” “us”, “our”). Our Website describes our work to design and eventually bring to market simpler, safer, and more effective solutions for optimizing insulin delivery.
Full name of legal entity: 
Name of DPO: 
Email address: 
Postal address: 
If you have concerns about how we are using your data, please contact our DPO with your concerns. You have the right to make a complaint at any time to the respective supervisory authority for data protection in your respective country. We would, however, appreciate the chance to deal with your concerns before you approach the respective supervisory authority in your country, so please contact us in the first instance.
Types of Data Collected, How we get it, and How we use it.
We may collect different types of personal and other information based on your use of our Website and our business relationship with you.
Personal Information may include:
• Contact Information that allows us to communicate with you — including your name, address, telephone number, and email address;
• Equipment, Performance, Website Usage, Viewing and other Technical Information about your use of our network, services, products or websites;
• The content of any message that you send us or your voluntary responses to any Surveys that we conduct.
We collect information in two primary ways:
• You give it to us;
• We collect it automatically when you visit the Website;
We may use the information we collect in a variety of ways, including to:
• Deliver products or services as ordered;
• Develop products or services or develop marketing plans for products or services as permitted;
• Provide you with the best customer experience possible;
• To respond to your questions;
• Communicate with you regarding service updates, offers, and promotions as permitted;
• Deliver customized content and advertising that may be of interest to you as permitted;
• Address network integrity and security issues;
• Improve our level of service; and
• Provide notifications on the latest site features.
Surveys and Personal Information
From time to time, we may request that users provide answers to Surveys that we provide via this Website or have hosted by a separate service. Your decision to provide responses to these Surveys is strictly voluntary, but these Surveys may collect and track your responses, which may include personally identifiable information (e.g., e-mail address, physical address, name), demographic information (e.g., education level, income, etc.), as well as any other responses that you provide. We will use the Survey responses to assist us in developing our products and services, develop marketing materials and plans for our products and services, and to identify people that might be willing to provide additional feedback. You should be aware that your Survey responses and any other Personal Information that you provide to us may be viewed both within [company name] and by trusted third parties. Accordingly, Users should careful to not provide Survey responses that include any Personal Information that they wish to keep private.
Online Activity Tracking
We collect information about your activity on the Website for a number of purposes using technologies such as cookies, Flash cookies, Web beacons, widgets, and server log files. To limit the use of Flash cookies from our Website, simply right-click on our site and adjust the Adobe Flash Player settings bar under “Local Storage” to your desired setting. Since cookies are now used as industry standard, most Web browsers automatically accept cookies, but you can usually change your browser to decline them. If you prefer not to enable cookies, you may choose to disable them; however, please note that certain features of our Website may not be available to you once cookies are disabled.
We may market products and services to you on the Website, as permitted by law and our policies. Our non-affiliated third party partners may use that information, as well as other information they or we may have, to help tailor the ads you see on our sites to you and to help make decisions about treatment options and other products. We will obtain your permission as necessary.
We may use your IP address and information about the site pages you visit to gather broad demographic information, as well as information about your interests and behaviors, to gain a better understanding of our customers and Users. For example, information may be used to analyze and improve our site design and functionality.
We do not sell your Personal Information to anyone for direct marketing purposes without your consent. Period.
Sharing With Affiliates:
Subject to applicable legal and our policy restrictions, [company name] and its corporate affiliates may share your Personal Information among themselves to make sure your experience with our Website is as seamless as possible.
Sharing With Non-Affiliate Third Parties:
Subject to applicable legal and our policy restrictions, we may share your Personal Information only with non-affiliate third parties that perform services on your or our behalf, and only as necessary for them to perform those services. For example, non-affiliate third parties may perform related services, including without limitation, maintenance services, database management, fulfillment, web analytics, and improvement of the features or functionality. Additionally, non-affiliate third parties may assist us in analyzing how our Website is being used. We require those non-affiliate third parties to protect any Personal Information they may receive in a manner consistent with our policies.
In Other Circumstances:
We may provide Personal Information to non-affiliate third parties for purposes such as:
• Complying with court orders, requests by government agencies and law enforcement officials and other legal process, or exercising our legal rights to defend against legal claims;
• Obtaining payment for products and services, including the transfer or sale of delinquent accounts to third parties for collection; and
• Transferring business assets, such as in connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy.
Please note that if you use any bulletin board, chat room, comment posting feature, or other public communication service, forum, or feature offered through or via the Website, or post any information available for viewing by other Users, any of the information that you share will be visible to other Users. The information that you make available can be read, used, and collected by other Users to send you unsolicited messages. We are not responsible for the manner in which the Personal Information that you decide to share will be used by other Users.
Anonymous & Aggregate Information
We collect some information on an anonymous basis. We also may anonymize the Personal Information we collect about you.
We obtain aggregate data by combining anonymous data that meet certain criteria into groups. When we employ non-affiliate third parties to anonymize or aggregate data on our behalf, as stated above, we require those non-affiliate third parties to protect any Personal Information they may receive in a manner consistent with this policy. We may share aggregate or anonymous information in various formats with trusted third parties, and may work with those entities to do research and provide products and services, as permitted by laws and our policies.
Safeguarding Your Information: Our Policy on Data Protection and Security
How Can You Control Your Personal Information?
We believe that choice in how and when you are contacted is key to customer satisfaction, so we offer several ways for you to update your contact information, change your preferences, or opt out of receiving future communications:
You may unsubscribe to any of our online email updates by following the unsubscribe instructions in the body of any email message.
You may write to us directly if you wish to: (a) update or delete your contact information; (b) ask that we not share your Personal Information with third parties; or (c) request that we cease sending you promotional or other information via mail or email. Such written requests should be sent to us using the contact information provided below. In those instances, we will retain your information in a “do not promote” file in our database or otherwise comply with the applicable law.
We will take commercially reasonable steps to implement your opt-out requests promptly, but you may still receive promotional information, as permitted by law and our policies, while updates to your records are being made.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Third Parties and Links
In the event that you provide Personal Information to any third party via any [company name] website or any offer made available to you by [company name], you understand that [company name] is not responsible for such third parties’ use or misuse of your Personal Information. You should review the privacy and information sharing practices of such third parties. Additionally, we may offer links to or from the Website it controls to other sites among our affiliates as well as to sites operated by third parties, as permitted by law and our policies, so that you can conveniently visit our vendors and advertisers or locate other content likely to be of interest. We are not responsible for the content, practices, or policies of sites operated by third parties and urge you to inquire about them before providing any personally identifiable information. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such site or resource.
California Privacy Rights/Other State Laws
California Civil Code Section 1798.83 entitles California customers and Users to request information concerning whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. California customers or Users who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us through the information provided below.