Privacy Policy for Patients
for Livongo-Insulia Study App

Voluntis Inc. and its affiliates (“Voluntis,” “our” “we” or “us”) own or control a mobile application (the “App”) and web portal (including livongo.insulia.com, the “Site”) that provides health care providers and their patients with access to and use of Voluntis’ Insulia® diabetes management companion software platform, which can be used on a computer, smartphone, tablet, or other computing device (collectively, whether accessed via the App or the Site, “Insulia”). Insulia is prescribed to you by your physician or other healthcare provider (your “Provider”). This Privacy Policy is integrated into and made part of the Terms of Use which users are required to accept at the time of their first login to the App or the Site.

What does our Privacy Policy Include?

This Policy describes how Voluntis collects, uses and shares information about you through Insulia. Please read this policy carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us as described at the end of this Policy. This Privacy Policy applies only to information we collect through the App and the Site. Insulia also contains links to third party sites that are not owned or controlled by Voluntis. We are not responsible for the privacy practices of such other sites. Voluntis does not share Personal Information (defined below) with those sites. We encourage you to be aware when you leave Insulia and to read the privacy statements of each and every website that collects personal information.

What Information Do We Collect?

We collect two types of information: (1) information we receive from you, and (2) information we receive from others. Information we receive from you includes information you share with us, such as when you use the Insulia mobile or web application and enter information about your blood glucose and other diabetes related information. It also includes information you provide us through technology, such as through a cookie placed on your computer when you visit our websites. We also receive information from other sources, such as your Provider, who provides and modifies your treatment plan to assist you in your diabetes management.

Information You and Your Provider Provide To Us

You and your Provider may provide us with “Personal Information” – information about you that can be used to identify you, such as (i) your contact information (e.g. name, phone number, email address), (ii) protected health information or other health or medical information that is in identifiable format (“Health Information”), and (iii) other non-public information that can be used to identify you (collectively, “Personal Information”). When we use the term “De-Identified Information”, we mean information about you from which you cannot reasonably be identified.
When your Provider prescribes Insulia, he or she prepopulates information to assist you in creating an account. The information that your healthcare provider enters into your account includes:

Your demographic data (name, birthdate, phone number and Email),
Your preferences (used unit of measure and language),
Your measures (current weight, height and A1c),
Your goals (blood glucose and A1c),
Your insulin prescription (insulin brand and injection schedule)
And the adjustment settings (frequency, thresholds, amounts) for your insulin injections.

When you use Insulia, request information from us, contact customer support, or otherwise communicate with us, you provide information to us. This Privacy Policy applies to this and other information that you provide to us. This information is associated with your account in order to facilitate your and your Provider’s use of Insulia for management of your condition.

Information We Collect Through Your Use of the Insulia mobile and web application

You also provide us information in other ways through technology. Some of this information may be linked to you personally.

Device Information: We collect technical information when you use our mobile and web applications. This includes information such as Internet Protocol (IP) address, the type of mobile device you use, your device operating system and browser type, a unique device identifier, the address of a referring websites, the path you take through our websites, and other information about your session on our mobile or web application.
Browsing Information: We use technologies such as cookies, web beacons, and mobile device identifiers to collect information about the use of Insulia. Cookies allow us to provide you relevant information as you use or return to Insulia. Web beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our website and other sites were effective. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Insulia features or services may not function properly without cookies. We use these tools to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you.

A Special Note about Children and Minors. Voluntis does not allow healthcare providers to create accounts for individuals under the age of 18 to use Insulia. If you are below the age of 18 you are not permitted to use Insulia.

How Do We Use And Share Your Personal Information?

We will not sell or rent your Personal Information. We may share your Personal Information in limited circumstances, such as to conduct our business, when legally required, or with your consent.
We may use your Personal Information for the following purposes (subject to applicable legal restrictions):

To provide you with Insulia, and to facilitate your Provider’s use of Insulia in connection with your treatment and care;
To create De-identified Information;
To create such as aggregate statistics relating to the use of Insulia;
To notify you when Insulia updates are available, and to otherwise communicate with you;
To personalize and enhance your experience when you use the Services, such as tailoring content and remembering your preferences;
To improve the content and functionality of our Services. For example, we may use our users’ demographics, interests, and behaviors to create new features and content; and
For any other purpose for which you give us authorization.

We may also disclose Personal Information that we collect or you provide (subject to applicable legal restrictions) as follows:

To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
To your healthcare providers for treatment, payment or health care operations purposes;
As required by law, which can include providing information as required by statute, regulation, subpoena, court order, legal process, or government request;
As directed by you;
To report, either directly or indirectly, to the federal Food and Drug Administration of adverse events related to drug products or medical device problems;
To a buyer or other successor in the event of a merger, dissolution, or other sale or transfer of some or all of Voluntis’ assets in which Health Information maintained by Insulia is among the assets transferred;
To our subsidiaries and affiliates;
As otherwise authorized by law; and
For any other purpose disclosed by us when you provide the information.

De-Identified Information. We may use and share De-Identified Information created by us without restriction.
Other Uses With Your Consent. In addition to the sharing described elsewhere in this Policy, we will share Personal Information with companies, organizations, or individuals outside of Voluntis only when we have your consent to do so.

How Do You Access and Update Your Personal Information?

You can access and update certain information we have relating to your account (name, date of birth, contact information and preferences) by signing into your account and going to the “ACCOUNT” section of our mobile or web application.
You can close your online account by contacting us as described at the end of this Policy. If you close your account, we will no longer use your online Personal Information or share it with third parties. We may, however, retain a copy of the information for archival purposes, and to avoid identity theft or fraud.

How Is Your Information Protected?

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, even with these safeguards, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us are not encrypted, and we strongly advise you not to communicate any confidential information through these means. You should report any security violations to us by sending an email to support@insulia.com or calling 1-617-229-6601.

Where Will Your Information Be Maintained?

Our Insulia USA mobile and web applications are hosted and managed on servers located within the United States. By using and accessing Insulia, you agree and consent to the transfer to and processing of Personal Information on servers located in the United States, even when you travel outside the United States, and you recognize that the protection of such information may be different than required under the laws of any location that you visit.

How Will You Know if This Policy Changes?

We may change this Privacy Policy from time to time in the future. We will post any revised version of the Privacy Policy on this page and at other places we deem appropriate. Continued use of our Service will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
If we make material changes that would impact your use of the Services, we will endeavor to notify you of the changes, such as by posting a notice directly on the Services, by sending an email notification (if you have provided your email address to us), or by any other reasonable method.

How Can I Contact You if I Have Questions?

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please email us at privacy@insulia.com or call 1-617-229-6601.

Last modified: February 2nd, 2019

Privacy Policy for Patients for Livongo-Insulia Study App