Type of Information We Collect
We collect information about you from different sources and in various ways when you use our Products and Services, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data. The information we collect about you (which we refer to as your "Personal Data") includes Registration Information, Health Information, Behavior Information, Demographic Information, Feedback Information, Online Identifiers and Metadata, Geolocation Information, Use Information, Voice Data, and Derived Information:
Information you provide directly:
- "Health Information" includes glucose readings, insulin and other medicines used and dosing information. You may enter this information into Sugarmate Products or Services manually, or link devices or applications that automatically upload this information. Health Information may also include data associated with glucose readings, such as date, time, and glucose monitoring device identifier, as well as any health thresholds you input to our Products and Services and notifications related to those thresholds.
- "Behavior Information" is information related to exercise, eating, and sleeping habits that you upload to our Products and Services. This information may be uploaded manually or may be uploaded automatically by linked devices or applications.
- "Demographic Information" includes age, diabetes type, gender and similar types of information.
- "Feedback Information" is information you submit to us in connection with your use of Sugarmate Products and Services, whether through our website, email, surveys or otherwise, regarding Sugarmate Products and Services, or other matters relating to us and our business, including the metadata relating to that information.
Information we collect automatically:
When you use our Products and Services, we collect some information automatically. For example:
- "Online Identifiers and Metadata" is information we receive from the computer, mobile phone, or other device you use in connection with Sugarmate Products and Services about that device. This information may include your IP address and other information regarding your computer, such as device identifiers, device type, your device's operating system, your internet service provider, the browser you use, and other software details including type, version, language, settings, and configuration. As further described in the Cookies, Mobile IDs, and Similar Technologies section below, our websites and online services store and retrieve cookie identifiers, mobile IDs, and other data.
- "Geolocation Information" If your mobile device has location turned on and you have given the Sugarmate app permission to access your location, we collect precise geolocation data when you use our Products and Services.
- "Use Information" includes your activities while using Sugarmate Products and Services, such as how often you open Software Apps and other activity regarding your use of the components of Sugarmate Products and Services.
- "Voice Data" refers to speech and voice data collected for Sugarmate's Speech Recognition and Dictation feature. You have the option to sync this feature with virtual digital assistant devices such as Amazon Alexa and Google Home. You must initiate this syncing and enable microphone permissions in Sugarmate Products and Services to do so.
Information we create or generate:
- "Derived Information" is information that we create by combining and/or analyzing Personal Data we collect from you.
Information we obtain from third-party sources:
- We may also obtain information, including health information, from third parties, such as device manufacturers, but only if you use their products or services or visit their websites and enable those third parties to share information with us.
When you are asked to provide Personal Data, you may decline. And you may use app or device controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain products or features, those products or features may not be available or function correctly.
Use and Disclosure of Information
- Registration Information: We use Registration Information to manage your account and Sugarmate Products and Services applicable to you, send you text messages and other notifications, and as otherwise described in this Policy. We also use your email address to contact you regarding your account. We will use your user account and Registration Information to link your use of Sugarmate Services and Software Apps with your use of Sugarmate Products.
- Health Information: We use this information to provide our Products and Services, send you notices, and personalize your experience and enjoyment using our Products and Services. We store this information on our servers, process it, and transmit it to the User, each Designated Recipient, and any third-party applications you link, where applicable. We may use this information for operations, administration and product development, maintenance and support.
- Behavior Information: Like health information, we use behavior information to provide our Products and Services and to personalize your experience using our Products and Services. We may share this information with Designated Recipients and any third-party applications you link to our Products and Services.
- Feedback Information: Feedback Information may be used by us and provided by us to our customers and third parties, in the form you provide as well as in excerpted, aggregated and anonymized forms, with or without attribution to you as the source. We may also use Feedback Information in our advertising, marketing and other communications with the public and in our business relationships, as well as in our internal communications, in each case with or without attribution to you as the source.
- Device Identifiers and Metadata: We collect Device Identifiers and Metadata Information, in connection with our provision of Products and Services and for our operations, administration and product development, maintenance and support. We may remove information that identifies you, and we may use such de-identified data for our business purposes as we determine, such as research and development, statistical purposes, product improvements, business operations and process improvements, marketing purposes, including disclosing such de-identified data to third parties for their use as we determine. We may share this information with our service providers.
- Use Information: We collect Use Information and store it on our servers, process it using our systems, and analyze it for our business purposes. We may also provide de-identified Use Information to third parties as we determine for their use. We may share this information with our service providers.
- Geolocation Information: We use Geolocation Information as necessary to provide services to you such as sending emergency alerts with your location to a Designated Recipient. We do not share this information with any third parties other than your Designated Recipient or as required by law. However, our third-party analytics providers may collect or infer Geolocation Information through their placement of cookies and similar technologies on our Products and Services.
- Voice Information: We collect Voice Information as necessary to provide Sugarmate's Speech Recognition and Dictation feature. We may share this information with our service providers.
- Personal Data and Solicitations: As permitted by applicable law, we may use Personal Data of you and your Designated Recipients, if applicable, to determine which emails and notices we send to you and your Designated Recipients, if applicable, including emails and notices regarding opportunities relating to our Products and Services (we refer to these emails as "Solicitations"). You may opt out of Solicitations by contacting us by email at support[at]sugarmate.io or by mail at the address listed in the "Contact Us" section below, and you may opt in again through one of those contacts. In the event we send promotional emails, such emails will include a link for opting out. We will try to comply with your request as soon as reasonably practicable. Please keep in mind that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
- Personal Data and Your Sugarmate Experience: We may use Personal Data belonging to you and your Designated Recipients, if applicable, to tailor your or your Designated Recipient's experience when using Sugarmate Products or Services and the content viewed when using such Products or Services. We may use Personal Data to manage these Products and Services, including the Website, to improve our business and provide new website and product and service features, and to otherwise manage our business, but without disclosing your Registration Information except as necessary for such purposes.
- Other Third Parties: In the ordinary course of our business, we will share Personal Data with companies we hire to perform services or functions on our behalf. We will not authorize those third parties to keep, use or disclose your Personal Data except for providing the services we have asked them to provide. We may also share your Personal Data with another company in conjunction with a corporate sale, merger, acquisition, or dissolution involving Sugarmate.
- Third-Party Analytics: Third-party analytics companies may also collect Personal Data through our website and apps including Use Information, Geolocation Information, Online Identifiers and Metadata, and inferences associated with Online Identifiers and Metadata (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement.
- De-Identification: We may "de-identify" your Personal Data by removing information that could identify you, and we may use such de-identified information for any purpose, except where we are required to do otherwise under applicable law.
Your Rights Concerning Your Personal Data
Access, correction, and deletion: If you wish to request access to, or correction or deletion of, Personal Data about you that we hold, or if you are a California resident and wish to request information about whether we have disclosed your personal information to any third parties for the third parties' direct marketing purposes, please email your request to privacy[at]sugarmate.io.
To the extent permitted by applicable law, we reserve the right to decline requests that we are not required to honor, unreasonable or excessive, where providing the data would be prohibited by law or could adversely affect the privacy or other rights of another person, or where we are unable to authenticate you as the person to whom the data relates.
Communications preferences: You can choose whether to receive promotional communications from us by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message. These choices do not apply to mandatory service communications that are part of certain of our products, or to surveys or other informational communications that may have their own unsubscribe method.
Choices for Cookies and Other Technologies: See the Cookies section for choices about cookies and other analytics and advertising controls.
EUROPEAN DATA PROTECTION RIGHTS
If the processing of Personal Data about you is subject to European Union data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, Personal Data;
- If any automated processing of Personal Data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the Personal Data in a usable and portable format;
- If the processing of Personal Data is based on your consent, you can withdraw consent at any time for future processing;
- You can to object to, or obtain a restriction of, the processing of Personal Data under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, contact us at privacy[at]sugarmate.io. When we are processing data on behalf of another party that is the "data controller", you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing Personal Data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests such as performing internal system audits, diagnosing and correcting technical problems; understanding how site visitors use our website; optimizing our website’s design and users’ experience, and making sure we’re providing you with relevant content.
Cookies and Other Technologies
Cookies: Cookies are small text files stored directly on your device that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well.
Web beacons: Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to the web server that hosts the image (typically hosted by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also may include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.
The third-party analytics providers we use on our websites include:
|Company/Service||Privacy Notices||Manage Settings (opt-out)|
|Google Tag Manager||https://www.google.com/policies/privacy/partners||https://policies.google.com/technologies/partner-sites|
|New Relic||https://newrelic.com/termsandconditions/services-notices||Email requests to PersonalDataRequests[at]NewRelic.com|
To learn about their privacy practices and how to opt-out from some types of their uses of cookie data, click on the links above.
Many of these companies are also members of associations, which provide a simple way to opt out of analytics, which you can access at:
- United States: NAI (http://optout.networkadvertising.org) and DAA (http://optout.aboutads.info/);
- Canada: Digital Advertising Alliance of Canada (https://youradchoices.ca/); and
- Europe: European Digital Advertising Alliance (http://www.youronlinechoices.com/).
Mobile advertising ID controls: iOS and Android operating systems provide options to limit tracking and/or reset advertising IDs.
Email web beacons: Most email clients have settings which allow you prevent the automatic downloading of images, which will disable web beacons in the email messages you read.
Do Not Track: Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Products and Services do not currently have the ability to recognize or honor browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls described above.
Privacy of Children and Adults with Guardians
Children's Online Privacy Protection: Sugarmate does not permit any person under 18 to subscribe directly to Sugarmate Services or Software Apps or to directly purchase Sugarmate Products. A parent or legal guardian may subscribe for a User who is under 18, but no person under 18 is permitted to use Sugarmate Products or Services without the express consent of a parent or legal guardian to the collection and use of the data and to the Sugarmate Terms of Service which require, among other things, that the parent or legal guardian is responsible for designating Designated Recipients, connecting the User Device to Sugarmate Products and Services, interacting in all ways with Sugarmate Products and Services, and ensuring that all communications with us come from the parent or legal guardian and not from the person under 18.
Adults With Guardians, Conservators or Other Legal Supervision: Sugarmate does not permit any person to subscribe directly to Sugarmate Products and Services or to directly purchase Sugarmate Products and Services if that person lacks the legal competence. A legal guardian, conservator or other person with the legal right to do so may subscribe for a User who lacks the legal competence, but no such User is permitted to use Sugarmate Products and Services without the express agreement of a legal guardian, conservator or other person with the legal right to provide such agreement to the Sugarmate Terms of Service, which require, among other things, that such legal guardian or other person is responsible for designating Designated Recipients, connecting the User Device to Sugarmate Products and Services, interacting in all ways with Sugarmate Products and Services, and ensuring that all communications with us come from the such legal guardian or other person and not from the User who lacks legal competence.
Our Retention of Personal Data
We retain Personal Data for as long as necessary to provide the products and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.
Terminating Your Account
You may terminate your Sugarmate account by following the instructions in the Sugarmate Software App.
Location of Processing European Personal Data: We transfer Personal Data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission's decisions on the adequacy of Personal Data protections, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
How We Protect Your Information
We take reasonable and appropriate steps to help protect Personal Data from unauthorized access, use, disclosure, alteration, and destruction.
To help us protect Personal Data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.
If you feel that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contact Us" section, below.
Phishing: We do not and will not, at any time, request Personal Data in a non-secure or unsolicited email or telephone communication. Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a priority for us. For more information about phishing, visit the Federal Trade Commission website
11075 Roselle Street
San Diego, CA 92121
Unites States of America
Because email communications are not always secure, please do not include credit card information or sensitive information in your emails to us.