PRIVACY POLICY



Last modified: January 17, 2024



Introduction



GlucoSense Inc. ("Company", "we" or “our”) respects your privacy and are committed to protecting it through our compliance with this policy.



This policy (this “Policy”) describes the types of information we may collect from you or that you may provide when you use, subscript, visit or view the following Platform, together with its pages, features and functions, and our practices for collecting, using, maintaining, protecting, and disclosing that information. 



  1. Our website: https://www.glucosense.ai/ and other related desktop and smartphone applications (our “Website”); and 



  1. glucose monitor, insulin pump, wearable, and connected health platform which are owned by you, used by you and/or connected to Company’s services (the “Equipment”).



Website and Equipment are collectively referred to as “Platform”. 



This Policy applies only to information we collect on or through our Platform. This Policy does not apply to information that we collect offline, or that you provide to, or is collected by any third party, which may have their own privacy policies that we encourage you to read before providing your information on or through them. This Policy also applies to your subscription or use of the services provided by Company (“Services”).



Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, please do not use our Platform. By accessing or using this Platform, you agree to the contents of this Policy. This policy may change from time to time. Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 



Children Under the Age of 18



You must have reached the age of majority to register as a member of or be permitted use of the Platform. Any information we receive from people we believe to be under this age will be purged from our database. 



We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our Platform or through any of its features, register on our Platform, make any purchases through our Platform, use any of the interactive or public comment features of our Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we find or are made aware that we have collected or received personal information from a child under 18 without verification of parental consent, we will make reasonable efforts to delete that information. Please note that the aforementioned removal does not ensure complete or comprehensive removal of such content or information posted on the Platform. If you are a parent or guardian of a child under 18 and believe that your child has disclosed personal information to us we welcome you contacting us as provided below so that we can address such matter.

California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see “Your California Privacy Rights” below for more information.



Information We Collect About You and How We Collect It



We collect information from and about users of our Platform, including information:



  1. By which you may be personally identified, such as name, postal address, e-mail address, telephone number, gender, age, IP addresses, any other identifier by which you may be contacted online or offline (“personal information”); and

  2. Details of transactions you carry out through our Website and of the fulfillment of your orders of products or use of your services. You may be required to provide financial information such as credit card information and billing address before placing an order through our Website; 

  3. Heath information, such as physical or psychological state of health (e.g., weight, glucose, insulin and laboratory data), disease or other ailments, medical history, medical treatment or diagnosis, health care provider information, activity metrics (e.g., steps taken, amount of exercise, calories burned, heart rate, and eating and sleeping habits); and

  4. About your internet connection, the equipment you use to access our Platform, and usage details.



We collect these information:



  1. Directly from you when you provide it to us.

  2. Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.



Information You Provide to Us  



The information we collect on or through our Platform may include:



  1. Information that you provide by filling in forms on our Platform. This includes information provided at the time of registering to use our Platform, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Platform.

  2. Records and copies of your correspondence (including email addresses), if you contact us.

  1. Your search queries on our Platform.

  2. Analytic tools and services, which are sometimes offered by third parties, and which track, measure and/or generate information about a website’s or program’s traffic, sales, audience and similar information, and which may be used for various reasons, such as, for example, statistical research, marketing research, and content ratings research, and conversion tracking. Google Analytics and Alexa are common examples of these types of technologies. We may also use other third-party analytic tools and services.

  3. Other third-party data tracking or analytic technologies (e.g., deep linking, eTags, device fingerprinting or cross-device tracking).



Information We Collect Through Automatic Data Collection Technologies  



As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:



  1. Details of your visits to and use of Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on our Platform.

  2. Information about your computer and internet connection, including your IP address, operating system, and browser type.



The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. Collection of this information helps us to improve our Platform and to deliver a better by enabling us to:



  1. Estimate our audience size and usage patterns.

  2. Store information about your preferences, allowing us to customize our Platform according to your individual interests.

  3. Speed up your searches.

  4. Recognize you when you return to our Platform.



The technologies we primarily use for this automatic data collection may include:



  1. Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform. 

  2. Flash Cookies. Certain features of our Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information section below.

  3. Web Beacons. Our Platform may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company, for example, to count users who have visited those pages and for other related Platform statistics (for example, recording the popularity of certain Platform content and verifying system and server integrity). 



How We Use Your Information



We use information that we collect about you or that you provide to us, including any personal information:



  1. To present our Platform and its contents to you.

  2. To provide you with information, products, or services that you request from us.

  3. To fulfill any other purpose for which you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. 

  4. To develop our Platform, products, and services.

  5. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  1. To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business.

  2. For testing, research, analysis, and product development, including to develop and improve our Platform. 

  3. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  4. To notify you about changes to our Platform or any products or services we offer or provide though it.

  5. To allow you to participate in interactive features on our Platform.

  6. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  7. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of our Platform is among the assets transferred.



  1. In any other way we may describe when you provide the information.

  2. For any other purpose with your consent.



Disclosure of Your Information



We may disclose, without restriction, aggregated information about our users, and information that does not identify any individual. 



We may disclose personal information that we collect or you provide:



  1. To contractors, service providers, and other third parties we use to support our business.

  2. To our affiliates.

  3. To 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the users of our Platform is among the assets transferred.

  4. For any other purpose disclosed by us when you provide the information.

  5. With your consent.

  6. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  7. To enforce our rights arising from any contracts entered into between you and us and for billing and collection.

  8. If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or the rights, property, or safety of our customers or others. 



We reserve the right to, but not the obligation, to share your information with the following:



  1. Company’s employees, agents, and administrators;

  2. Company’s accountants, financial advisors, and legal advisors;

  3. Company’s parents, subsidiaries, and affiliates;

  4. In connection with any clinical research or clinical research trial in which Company is participating or otherwise facilitating, any sponsor or principal investigator of such clinical research or clinical research trial;

  5. Service providers and other third parties who help Company provide, manage, administer, maintain, monitor, distribute, operate, or facilitate the Site and/or the App, who help Company develop, market or provide its products and services, or who help further Company’s business efforts, e.g., web hosting companies, website administrators, mobile app distribution platforms, support services companies, data analytics and analysis companies, advertising partners, and payment processing vendors (including, for example, through the Apple App Store), as needed in order for them to perform such services;

  6. Law enforcement or other governmental entities in response to what Company believes to be an allegation or suspicion of illegal activity, a request relating to a civil or criminal investigation, an allegation or suspicion of illegal activity, a subpoena, a court order, or any other activity that may expose Company to liability if it does not act or comply;

  7. Any third parties who Company believes are necessary to help or allow Company to protect and enforce its rights and properties, including, without limitation, to enforce its rights under Company’s Terms of Use or any other agreements it has with you, and to protect and enforce its intellectual property rights; and/or

  8. Any third parties who Company believes are necessary to help or allow Company to protect the rights and properties of others (which may include you), assuming that Company believes it has an obligation to do so.



Company also reserves the right to share your personal information with third parties in connection with or as a result of any potential or actual merger, acquisition or other event involving a change in ownership or control of Company or Company’s business (whether by sale of assets, merger, stock purchase or otherwise).



Company also reserves the right to use data collected on, through, or in relation to the Site and/or the App (including, without limitation, your personal information) for use in conducting medical research, studies, and publications (and any other research, studies, and publications) and to share the same with third parties; provided, however, that any such use of such data will be on an anonymized basis.



Company does not limit the ways in which it might use or share non-personal information – and Company reserves the unencumbered right, but not the obligation, to use or share non-personal information – because non-personal information does not identify you.  For example, Company may freely share non-personal information with its parent, subsidiary and affiliated companies, its vendors, its suppliers, its representatives and its customers, as well as with other individuals, businesses and government entities.



You may choose to share certain information and/or follow other users on the Platform. You may choose to share your contact information with other users or provide it publicly.



Choices About How We Use and Disclose Your Information



This section describes mechanisms that we provide for you to control certain uses and disclosures of your information.



  1. Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may become inaccessible or not function properly.

  2. Promotions from Us. You can opt-out of receiving certain promotional materials by selecting “unsubscribe” in emails we send to you. 



California residents may have additional personal information rights and choices. Please see Your California Privacy Rights section below for more information.



Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated email address/number: support@glucosense.ai. However, please note we do not currently sell data in a manner which will trigger that statute’s opt-out requirements.



Accessing and Correcting Your Information



You can update any personal information on your account profile through the Platform, or contact us at the contact information listed in Section XII. Contact Information.



Users of both of our Platform may send us an email to us at support@glucosense.ai to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.



Your access to and use of information provided on the Platform is governed by our Membership Policy.



California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” below for more information.



Your California Privacy Rights (“California Notice”)



The following additional privacy notices for California residents (the “California Notice”) supplement the information contained in the other portions of this Policy and apply solely to individuals who reside in the State of California (“California consumers” or “you”). We adopt this California Notice to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and their related regulations (collectively the “California Privacy Law” or the “CPL”) and other applicable California laws.



Overview of Consumer Rights Under the CPL.



Under the CPL, California consumers have certain rights regarding their personal information, including:



  1. The right to know the categories of personal information that we have collected and the categories of sources from which we obtained such information.

The right to know our business purposes for sharing personal information.

  1. The right to know the categories of third parties with whom we shared personal information.

  2. The right to know if we sold or disclosed your personal information for a business purpose, comprising two separate lists disclosing: (1) any sales, which list identifies the personal information categories that each category of recipient purchased (note that at present we do not sell personal information that we collect); and (2) any disclosures for a business purpose, which list identifies the personal information categories that each category of recipient obtained.

  3. The right to access the specific pieces of personal information that we have collected

  4. The right to correct personal information that we have collected.

  5. The right to delete your personal information.

The right to not be discriminated against if you exercise your rights under the CPL.



The provisions below of this California Notice provide further details about these and other rights and certain details about the exercise of such rights.



Information We Collect.



We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer, household or device (collectively, "personal information"). Personal information does not include:



  1. Publicly available information from government records.

  2. De-identified or aggregated California consumer information.

  3. Information excluded from the CPL’s scope, including:

  4. Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and

  5. Personal information covered by certain other laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.



We have collected the following categories of personal information from consumers within the last twelve (12) months: 



CategoryExamplesCollectIdentifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.YESPersonal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories. (Note: Certain of the above information may be considered to be sensitive personal information under the CPL and, to the extent such data is considered to be sensitive personal information you have the right to limit the use and disclosure of such data.)YESProtected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).YESCommercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.NOBiometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.YESInternet or other similar network activity.Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.NOGeolocation data.Physical location or movements. YESSensory data.Audio, electronic, visual, thermal, olfactory, or similar information.NOProfessional or employment-related information.Current or past job history or performance evaluations.NONon-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NOInferences drawn from other personal information.Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.YES



Sources of Personal Information



In addition to sources of personal information addressed elsewhere in this Policy, we obtain the categories of personal information listed above from the following categories of sources:



  1. Directly from you. For example, from submitting information to us via our Platform.

  2. Indirectly from you. For example, from automatically collecting certain information related to your activities on our Platform, such as your Internet Protocol (IP) address, your device operating system, your browser type, your devices’ unique device identifier, the address of a referring website, the path you take through our Platform, and other information about your session on any of our Platform. We may use Cookies, Flash Cookies, Web Beacon, and Embedded Scripts. 

From Affiliates. We may collect personal information about you from our affiliates or others acting on their behalf.



Uses of Personal Information



In addition to uses of personal information addressed elsewhere in this Policy, we may use or disclose the personal information we collect for one or more of the following business purposes: 



  1. To present our Platform and their contents to you.

  2. To provide you with information, products, or services that you request from us.

  3. To fulfill any other purpose for which you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. 

  4. To develop our Platform, products, and services.

  5. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  1. To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business.

  2. For testing, research, analysis, and product development, including to develop and improve our Platform. 

  3. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  4. To notify you about changes to our Platform or any products or services we offer or provide though it.

  5. To allow you to participate in interactive features on our Platform.

  6. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  7. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of our Platform is among the assets transferred.

  8. In any other way we may describe when you provide the information.

  9. For any other purpose with your consent.




We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.



Disclosures of Personal Information for a Business Purpose



We may disclose your personal information to a third party, such as service providers, for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 



In the preceding twelve (12) months, we have not disclosed personal information for a business purpose. 



Sales of Personal Information 



In the preceding twelve (12) months, Company has not sold personal information.



Your Rights and Choices 



The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.



Access to Specific Information and Data Portability Rights



You have the right to request that Company disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:



  1. The categories of personal information we collected about you.

  2. The categories of sources for the personal information we collected about you.

  3. Our business or commercial purpose for collecting that personal information.

  4. The categories of third parties with whom we share that personal information.

  5. The specific pieces of personal information we collected about you (also called a data portability request).

  6. If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.



Deletion Request Rights. 



You have the right to request that Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. In addition, if you provide us with a verifiable consumer request to correct inaccurate personal information that we maintain about you, we will use commercially reasonable efforts to correct such information in accordance with your instructions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 



We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 



  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  3. Debug products to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise other rights provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  8. Comply with a legal obligation.

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.



Exercising Access, Data Portability, and Deletion Rights



To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through the contact information in Section XII below, entitled “Contact Information”.

 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 



You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:



  1. Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.

  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

  3. We cannot respond to your request or provide you with personal information if we cannot verify your identity, or authority to make the request, and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. 

  4. We will only use personal information 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 a verifiable consumer request within forty-five (45) days of its 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 information 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 of your CCPA rights. Unless permitted by the CCPA, we will not:



  1. Deny you goods or services.

  2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  3. Provide you a different level or quality of goods or services.

  4. 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 the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information'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.   



Retention of Personal Information

Our policy is to retain personal information only for as long as is necessary to fulfill the reason for which the personal information was collected and as necessary to process such personal information. In addition to the above, we will retain your personal information for the purposes of satisfying any professional, legal, accounting or reporting requirements to which we are subject. To determine the appropriate retention period for personal information, we consider the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we collected and processed your personal information and whether we can reasonably achieve those purposes through other means, as well as any applicable legal and professional requirements.



Other California Privacy-Related Disclosures



  1. Sharing Personal Information for Direct Marketing Purposes. Before sharing personal information of California consumers with third parties for direct marketing purposes we will obtain opt-in consent from the applicable California consumers or provide such California consumers with a cost-free method to opt out.

  2. California Do-Not-Track Disclosure. At this time, the Service is not set up to honor web browser do-not-track settings.  Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to Platform or applications requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org.

  3. Information on Marketing Disclosures. California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the email or postal address found below in Section XII “Contact Information”.

  4. Content Removal Requests for Service Users Under 18 Years Old. If you are a Service user under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on the Service. You may send us any such requests by one of the following methods: (i) by email (writing “Privacy Policy/Removal Request” in the subject line) at support@glucosense.ai; or (ii) by writing to us at the postal address found below Section XII “Contact Information”.  We will review the request and respond promptly.  You should be aware that a request to remove content or information posted by you on the Service does not ensure or require complete or comprehensive removal of such content or information from our databases.



Your EU Privacy Rights



Persons who are residents of the member countries of the European Union (EU) or other data subjects covered by the EU’s General Data Protection Regulation, 2016/679 (GDPR), have certain additional privacy rights under applicable law. To learn more about your EU privacy rights, please check the applicable sections below.



Legal Bases for Processing Personal Information of European Union Citizens



When processing your personal information, Company may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances:



  1. Legitimate Interests. We may process your personal information where Company has a legitimate interest in such processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms.

  2. Consent. We may process your personal information where Company has obtained your consent to the processing.

  3. Contractual Necessity. We may process your personal information where such processing is necessary in connection with any contract that Company has with you.

  4. Legal Requirements. We may process your personal information where such processing is required by applicable law.



Disclosures to Third Parties



Your personal information will not be disclosed to third parties except where it is necessary for fulfillment of Company’s obligations to you or where Company is obliged or permitted to do so by law (including, without limitation, through the terms of any agreement Company may have with you), or where Company makes disclosures that are otherwise consistent with the uses described in this Policy.



Company may also disclose any information (including personal information) relating to you to law enforcement authorities or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.



Company reserves the right to transfer any personal information Company has about you in the event Company sells or transfers all or a portion of our business or assets, or merges with another organization. Should such a sale, transfer or merger occur, Company will use reasonable efforts seeking to require that the transferee uses personal information you have provided to Company in a manner that is consistent with this Policy.



We will not sell, resell or lease your personal information to any third parties but Company may, if required for the purpose(s) for which your personal information was collected and processed, share it with Company partners and/or service providers to enable them to provide their services to Company or to you, as applicable. The foregoing are in addition to the other uses described elsewhere in this Policy.



Security of Personal Information of European Union Citizens



Company has policies and technical and organizational measures in place which are intended to safeguard and protect your personal information against unauthorized access, accidental loss, improper use and disclosure. However, you should be aware that information transmitted over the internet is not completely secure because of the nature of the internet and that systems and measures used to secure information are not flawless. For these reasons, although Company will use reasonable efforts to protect your personal information, Company does not warrant the security of personal information transmitted to Company or stored by Company, and personal information that is transmitted to Company by you electronically is done at your own risk.



Retention of Personal Information of European Union Citizens



Our policy is to retain your personal information only for as long as is necessary to fulfill the purposes for which Company collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which Company is subject. To determine the appropriate retention period for personal information, Company considers the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which Company collected and processed your personal information and whether Company can achieve those purposes through other means, and any applicable legal and professional requirements.



Your Rights as a European Union Citizen



You have a number of rights concerning your personal information that Company holds and uses, including the following:



  1. Right of Access. You have the right to be informed about what personal information Company holds about you and to a copy of this personal information.

  2. Right to Rectification. You have the right to have any inaccurate personal information which Company holds about you updated or corrected.

  3. Right to Erasure. In certain circumstances you may request that Company delete the personal information that Company holds about you.

  4. Right to Complain. You have the right to lodge a complaint regarding the processing of your personal information to an applicable governmental or supervisory authority in your country.

  5. Right to Withdraw Consent. Where processing of personal information is based on your consent, you have the right to withdraw such consent at any time.

  6. Right to Object. Where Company relies on its legitimate interests to process your personal information, you have the right to object to such use and Company is required to discontinue such processing unless Company can demonstrate an overriding legitimate interest in such processing.

  7. Right to Restriction. You have the right to request that Company stop using your personal information in certain circumstances including if you believe that the personal information Company holds about you is inaccurate or that Company’s use of your personal information is unlawful. If you validly exercise this right, Company will store your personal information and will not carry out any other processing until the issue is resolved.



  1. Third Party Applications and Networks 



The Platform and/or any communications sent through or as a function of Platform might contain links to third-party websites, networks, platforms, servers and/or applications. Third-party websites, networks, platforms, servers and/or applications might also contain links to the Platform.



In addition, you might have the opportunity to access the Platform using your online user accounts with certain third-party websites, networks, platforms, servers or applications, which might be subject to separate privacy policies pertaining to those third-party websites, networks, platforms, servers or applications. Company might also collect information from those third-party websites, networks, platforms, servers or applications (such as, for example, your name, gender, date of birth and personal interests, when you “like” or click links provided by or through those third-party websites, networks, platforms, servers, or applications and other information available through your online account or page with those third-party websites, networks, platforms, servers or applications).



Moreover, Company might permit third parties to use their own tracking, data aggregation and/or data analysis technologies like the ones described above (e.g., third-party cookies). 



To the fullest extent permitted by law, Company is not responsible for, and you hereby release Company from any and all liability which may arise from, such third-party websites, networks, platforms, servers and applications. It is your responsibility, and your responsibility alone, to carefully read, accept and comply with any and all relevant terms of use, waivers, and privacy policies associated with those third-party websites, networks, platforms, servers and applications.



Data Security



We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of our Platform like message boards. The information you share in public areas may be viewed by any user of the Platform.



Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.



Changes to Our Privacy Policy



If we make material changes to how we treat our users' personal information, we will post the updated version of the privacy policy on the Platform together with the policy's updated effective date. Your continued use of our Platform following the posting of changes constitutes your acceptance of such changes. The date this Policy was last revised is identified at the top of the document. You are responsible for ensuring that we have an up-to-date, active and deliverable email address for you, and for periodically visiting our Platform and this Policy to check for any changes.



Disclaimer of HIPAA Applicability



Company is not a “covered entity” as defined in the federal medical record privacy statute known as the Health Insurance Portability and Accountability Act of 1996, as amended, and the regulations issued under that law (“HIPAA”). Additionally, with respect to the personal information that Company will obtain about you, Company does not anticipate that it will ever be a “business associate” under HIPAA, since the companies Company works with are not “covered entities” under HIPAA. Therefore, even though your personal information contains medical information that is the type of information commonly protected under HIPAA, it is not subject to any of the protections available to you under HIPAA. HIPAA is inapplicable to Company’s relationship with you.




Contact Information



To ask questions or provide comments about this Policy and our privacy practices, contact us at: 



GlucoSense Inc. 

Email: support@glucosense.ai