Your privacy and confidence are and have always been a priority for Insulcloud S.L. and its subsidiaries , Insulcloud Delivery S.L.U.and Insulcoud Factory S.L.U. (hereinafter Insulcloud). In this Privacy Policy we explain in a simple way how we use the personal information you provide us through our websites. Insulcloud guarantees that we have taken all appropriate measures to provide security and protection to the personal data that you provide through the website. This Privacy Policy applies to insulclock.com, tudiabetesbajocontrol.com, www.glucowatch.eu, shop.insulclock.com and demo.endo.insulclock.com including all pages, sections and sub-sections (hereinafter referred to collectively as "the website", "our website" or "this website"). If you leave our website through a link or visit our social media pages, you will also leave the scope of this Privacy Policy. Because the services and products offered by Insulcloud make data processing necessary, this Privacy Policy complements the Privacy Policy and the Legal Notice and Terms of Use of the Insulclock System. The Insulclock System consists of a device hooked up to a disposable insulin pen, a mobile application and a web platform. Please read carefully the contents of this section and, if you have any doubts regarding the treatment that Insulcloud does with your data or any other aspect of this Privacy Policy, please do not hesitate to contact our Data Protection Officer, who will get in touch with you as soon as possible. Due to legal changes as well as the organizational changes that may occur in Insulcloud, this Privacy Policy may change, so we recommend that you review it periodically. However, in case we consider that the changes introduced are important, we will contact you through the contact information you have provided, if applicable. If you do not agree with anything, in whole or in part, of what is detailed here and accept our Legal Notice and Terms of Use, please stop browsing our website and do not use any of our services.  

Who will be responsible for processing your personal information?

The information you provide us through this website will be responsibility of Insulcloud. In order to you can identify us and, if you wish, contact us, we provide you with our data:
  • Owner: Insulcloud, S.L.
  • Trade name: Insulcloud
  • Registered at: Madrid Business Register in volumen 32823, sheet 103, section 8, paper M590850 on 22nd October 2014
  • VAT: ESB87131454
  • Registered Office: Avenida de Sabino Arana 8, 2ª, 48013 Bilbao, Bizkaia (Spain)
  • e-mail: legal@insulclock.com
 

What is Personal Information?

It is about any information that relates to an identified or identifiable natural person. An identified or identifiable natural person is one whose identity can be determined, directly or indirectly, in particular by means of an identifier element (for example: name, email or identification number). We collect, store and use your personal information when necessary to provide you with some of our services and for the development of our business, as described in this Privacy Policy. Our intention is that you are permanently informed on how Insulcloud treats the personal information about you, so we ask you to contact us as long as you have any questions in this regard.  

What personal data do we collect?

To browse this website it is not necessary to register or provide us with any personal information beyond those automatically collected. However, we offer certain services that require you to provide us with some personal information in order to provide the service:
  1. Subscription to news (newsletter service). To access this service we offer, you must provide us with your email address, which we will only use for to receive updated information on treatment, diabetes education, healthy living, exercise and nutrition and on the latest news from Insulcloud. This information delivery service is provided through the company MailChimp. We strongly recommend you to carefully read Mailchimp's Privacy Policy, Legal Terms and Cookies Policy
  2. Contact us. This website offers the possibility to contact us to request additional information about our company or our products. We only need you to provide us with an email address, which will be used to resolve any questions you may have or send you the information you have requested, if possible. We inform those who send us their curriculum vitae by e-mail or thruogh the contact section enabled on this website, that, if the profile matches the one requested by the company, data will be incorporated into the Human Resources file whose head is Insulcloud. Your data will be processed in order to manage a possible candidate selection process. If the candidates do not want the processing of their data to be carried out for the indicated purpose, or wishes to exercise their rights, they must write to Insulcloud at the address indicated above or by contacting our Data Protection Officer.
  3. Registration on our online store: Our website offers you the possibility to buy Insulclock® device through our online store, to which you will be redirected from insulclock.com and to which it is also applicable this Privacy Policy. In order to send your order and complete the purchase process, including the billing process, we need you to provide us with the following personal information: name, surname, ID number, address (street, location, estate, country and post code) in which you will receive your order, an e-mail, a phone number, credit or debit card data, as well as the type of Insulclock® you want to buy. Make sure that you order an Insulclock® device compatible with your insulin pen.
  4. To proceed with the payment of the Insulclock® you select to purchase. Insulcoud will never process your bank details that you provide, since they are directly processed by the platform Stripe. Stripe Inc. is a compny stablished out of European Union borders, so we have ensured that is an U.S. company adhered to Privacy Shield. We recommend you to carefully read  the Privacy Policy, Legal Notice and Cookies Policy that Stripe Inc. makes available to the general public. Before making a purchase in our online store we recommend that you read carefully the General Purchasing Conditions.
  5. To provide you with a demo of the Endo.Insulclock platform. You you are a healthcare professional we give you the opportunity to use a simulator of our Endo.Insulclock platform, in which you will be enabled to see how Insulclock shows the information related to a patient with diabetes. For that, we need you to give us your name, an e-mail, your phone number, adress and the name of the hospital or healthcare institution in which you develop your professional activity.
When you provide us with some information of a personal nature, you guarantee us that the information is true, accurate, without limitations or reservations, and that you provide it to us freely and give your consent for its treatment in accordance with what is established in this Privacy Policy, and you understand and accept the Legal Notice and Terms of Use and our Cookies Policy. Please, if there is any variation in the data you have provided, please let us know by sending an email to legal@insulclock.com. Our website also receives and collects information automatically through cookies and other technologies: your domain name; your browser type and your operating system; web pages you see; links that you click on; your IP address; the amount of time you visit our Site and/or use our Services; and the reference URL or the webpage that took you to our site. Please, read our Cookies Policy for further information. This information is collected to help us manage, protect and improve our services, analyze their use and improve the user experience. We may automatically combine the information collected with other information we have about you.

Google Services.

We use Google Anlitycs in our website to obtain and analyze your browsing information. This digital tool, developed by Google, provides an audience and traffic analysis of our website. Google Analitys does not collect name, surname or adress from which you connect to our website. The obtained information is ralated with the number of visted pages, language, used browser, the operator from which the visit is made and the IP address from which the user accesses, among others. Google uses a cookie to obtain the information about your use of this website (your IP) and stores this information in USA. However, your IP address will be shortened (and therefore anonymous) before the transfer by Google in Member States of the European Union or in other States that have signed the Convention on the European Economic Area. Only in exceptional cases the IP address is transmitted completely to a Google server in the United States and shortened there. Google will analyze the information obtained in order to prepare reports on the activities of the website and to provide us with additional services. The IP address transmitted by your browser in the framework of Google Analytics will not be combined with other Google data. See our Cookies Policy to know more. In addition to blocking all cookies in the browser, you can prevent the processing of this data through Google by downloading and installing the browser plug-in available through the following link. Alternatively to the browser plug-in, especially in browsers of mobile devices, you can prevent registration by Google Analytics by establishing an opt-out cookie that prevents future registration of your data when visiting this website (the opt-out cookie is only valid in this browser and for this domain, so if you delete the cookies from this browser, you must click on the link again): Deactivate Google Analytics. Furthermore, this website uses the Google advertising tool Google Adwords, including the conversion and remarketing function. The remarketing tool allows us to display personalized advertising on other websites that you visit. To do this, Google analyzes your use of our website and stores the corresponding ID in your browser. This ID allows us to assign you to a specific group of users and can recognize you when you visit a website that is part of the Google advertising network. These websites may now display ads related to your use of our website. During this process Google does not collect any personal data from you, this assignment takes place exclusively through your browser. The data collected will be stored and processed in the United States. We use conversion tracking to determine the success of advertising our services on other websites. To do this, a conversion cookie is generated by clicking on one of our ads. This cookie allows us to recognize that you have reached our website through this announcement. Thanks to these usage statistics we create statistics to evaluate the conversion of our ads. We do not receive personal information about you.  The conversion cookie set of your browser is individual and cannot be used by other Google AdWords customers for their statistics.  You can avoid this remarketing by deactivating the function. Both Google Analytics and Google AdWords are tools developed by Google. Since Google is a company whose headquarters are outside the borders of the European Union, we have ensured that it is an American company adhered to the Privacy Shield. You can get more information about Google Analytics in the Google data protection declaration, as well as more information about Google AdWords by clicking here.  

Facebook services

Our website uses the so-called Facebook pixels or Custom Audience. It is about a function of a Facebook web analysis service. Facebook pixels are non-visible graphic files integrated into our website. When you visit our website, information about the pixel is stored in the browser. Then we can know whatsubpages have you visited. We share this information with Facebook, on the one hand to better adapt our advertises to your interests, and, on the other hand, to analyze the eficiencie of our advertices in Facebook. Depending on the use that you do of our website, you will be assigned to certain interest groups called custom audiences. The information generated by cookies is usually transferred to a Facebook server in the United States and stored there. You can get more information about data collection using Facebook tracking pixels here or here. We have no influence on Facebook's data processing operations. Facebook uses the data for advertising, market research and bid optimization purposes. In this regard, Facebook's privacy policy applies. Please note that the use of these tracking methods allows the identification of users through numerous websites. You can disable this feature in your Facebook account settings for all the devices or terminals you use. Since Facebook is a company whose headquarters are outside the borders of the European Union, we have ensured that it is an American company adhered to the Privacy Shield. For more information, see Facebook's Privacy Policy and Terms of Service.

Data of Minors

We want to let you know that this website is aimed exclusively at a public over 18 years old (minors who intend to make use of the services contained in the website must have the prior consent of their parents, guardians or legal representatives, these being the only responsible for the acts carried out by the minors in their charge). If we detect that a minor is making use of this website, we will request an authorization from their parents or legal guardians. Once the consent has been obtained, the minor's parents or legal guardians may obtain access to the minor's data and to the account that the minor may eventually create. The parents or legal guardians of the minor may express their wish to terminate the processing of the minor's data at any time, through a request to Insulcloud so that the minor's account is deleted, sending an email to legal@insulclock.com or by sending a letter to Insulcloud S.L., La Nave, Calle Cifuentes 5, 28021 Madrid (Spain), accompanied by a photocopy of the ID card and a photocopy of the family book. We will eliminate the minor's account, but we will keep general information that is not identified and that we are obliged to keep in order to comply with current legislation.  

What do we use your personal information for?

Insulcloud will use your personal data with the utmost caution to ensure adequate protection of your personal information, adjusting to current legislation at all times and we will do as explained below:
  • To improve your user experience and facilitate your future purchases through this website. We use this information to set up and manage your customer account, offer technical assistance, after sales and training services, verify your identity and send important information related to your account, your subscription and your purchase order.
  • To solve your technical doubts, including functioning problems, solving incidences or to solve any other kind of doubt or for receiving and responding any kind of comment you want to put in our knowledge.
  • To send you upgraded information about your treatment, diabetic education, healthy lifestyle, physical activity and nutrition, if you desire it so.
  • To send you personalized marketing information related with your interests. Do not worry, you will always have the opportunity to regret receiving this kind of communications.
  • Because of legal issues, it is possible that we are obligated to keep and use personal data, as may occur for prevention, detection or investigating a crime or a fraud possible threats to people safety, infractions of this privacy policy or as an evidence in eventual legal proceedings in which Insulcloud be a party. It is possible that your personal data is under the legislation of third countries and, according to that, it is accessible by the government, tribunals, security bodies or regulatory entities of said countries. Moreover, it is probable that we use your personal data to comply with internal security audits requirements for the protection of your data or another issue we consider as necessary. These uses will always be covered in:
    1. current laws, including those applicable outside your country of residence;
    2. a request from a court or tribunal, a security or regulatory body, as well as other public authorities, including those that come from outside your country of residence;
    3. compliance with this Privacy Policy, our Legal Notice and Terms of Use and our Cookies Policy; and
    4. protection of our rights, privacy, security or property, or those of other people.
As mentioned above, our website also receives and collect automatic information. This information is collected to help us to manage, protect and improve our services, analyze their use and improve the user experience. We may automatically combine the information collected with other information we have about you. Please, read our Cookies Policy for obtaining further information.  

Do we share your personal information?

We only share your personal information with our suppliers, in particular with the company responsible for sending you the Insulclock® device that you can buy in our online store. You can obtain more information regarding the courier company that provides us the shipping services in the General Purchasing Conditions. The courier company that currently provides us with the shipping service is DHL (Deutsche Post AG), whose Privacy Policy can be consulted in the following link Moreover, to process your payment order, we use the services of Stripe platform. Since Stripe Inc. is a compny stablished out of European Union borders, so we have ensured that is an U.S. company adhered to Privacy Shield. We recommend you to carefully read  the Privacy Policy, Legal Notice and Cookies Policy that Stripe Inc. makes available to the general public. We will not transfer your personal information to third parties, except in connection with the sale, merger or transfer of a line or division of our products or the Insulcloud company, so that the buyer may continue to provide information and services. To avoid doubts, we will not sell your personal information to third parties for commercial purposes and we will only share your personal data with third parties to the extent that you have given your consent or as permitted by applicable law.  

Where do we store your personal data?

The personal information that you provide us for the management of the purchases, as well as the rest of the information that we collect in our website is hosted in the cloud, in a secure way, by Google Cloud Platform, a digital tool developed by Google. Given that Google is a company whose headquarters are outside the borders of the European Union, we have ensured that it is a North American company adhering to the Privacy Shield. We take steps to ensure that the information we collect is processed in accordance with this Privacy Policy and in accordance with the requirements of applicable law, regardless of the location of the data. We guarantee that in the event that we are obliged to provide your personal information to our suppliers, present or future, with the purpose of providing us with support for possible incidents of the system of this website, said third parties will be obliged to maintain and protect the confidentiality of your personal information and use it only to the extent that it is absolute and strictly necessary.  

How do we protect your personal data

Given the "core" of Insulcloud, the protection of your personal information has always been, is and will be a key principle of our company. That is why we use and have put in place all the legal, administrative and technical mechanisms to guarantee the protection of your personal data. Your personal data are protected. Insulcloud restricts the access of its employees to your personal information only in those cases or situations in which such access is strictly necessary to provide a good service or to guarantee the security thereof. It is important to keep in mind that no data transmission made over the Internet is perfectly safe, so we advise you to take precautions whenever you share personal information through the network. Also keep in mind that only you are responsible for protecting the account access data you have created on this website, so we recommend you to pay attention to not leaving user sessions open, create a password that only you know and that it cannot be easily guessed, as well as not sharing with anyone the keys or access data to your account. We are not responsible in case of loss or theft of your access password, or of the activities that may be carried out by unauthorized users with your user account, in case you are responsible for unauthorized access. However, at Insulcloud we are here to help you, always and at all times, so if you have proof or suspicion that your account may have suffered unauthorized access or that your personal information may be compromised, please contact our Data Protection Officer as soon as possible.

How long do we store your personal information?

We will safeguard and retain your personal information for as long as necessary and reasonable in accordance with current legislation and according to commercial matters. To determine these times or periods of conservation, Insulcloud will observe the provisions of local laws and contractual obligations. When we no longer need your personal information, we will remove it from our servers, records and databases in a secure manner. We keep your personal data to provide a quality service on our website and for legitimate and essential business purposes, such as maintaining the performance of the website, making business decisions based on data about new functions and offers, fulfilling our legal obligations and resolve disputes. We keep some of your personal data while you are registered as a USER on our website. If you request it, we may delete or anonymize your personal data so that it is not identified, unless, legally, we can or are required to keep certain personal data, including the following cases:
  • If there is an unresolved problem related to your order, such as pending credit in your account or an unresolved claim or dispute, we will retain the necessary personal information until the problem is resolved;
  • When we are required to retain personal data to comply with our legal, fiscal, accounting and auditing obligations, we will retain the necessary personal data during the period required by applicable law; and/or,
  • When necessary for our legitimate business interests, such as preventing fraud or maintaining the safety of our users.
 

What rights do you have regarding your personal information?

The current legislation on Data Protection gives you rights. Insulcloud ensures that your rights are respected and we guarantee that you can always exercise them. You have access right to your data as well as to have control over them and know how we treat your personal information at Insulcloud. You have the right to freely access the personal information that we have about you. To exercise your right contact con us. We will ask you to identify yourself properly, through a proof of identity, then, so before providing your personal information we must verify your identity. Once the identity verification procedures are completed, we will provide you with this information as soon as possible, which will never be longer than one month (30 days) from the date you submitted your request. You also have right of rectification of your personal data, that is, you have the right to modify your personal data that is inaccurate or incomplete. You may request this rectification contacting us, indicating what data it refers to, as well as the correction that must be made and it must be accompanied by the supporting documentation of the request, since in this case we must verify your identity. Once your request has been received, we will proceed to rectify your data within a period no longer than 10 days. The right of cancellation also assists you, which implies the request of cancellation of data of yours that is in our power, that is unnecessary or not pertinent for the purpose for which it was collected. The data will be blocked, that is, it will be identified and reserved in order to prevent its processing. We will proceed to agree the cancellation of the personal data on which the right is exercised, and we will do it within 10 days from the reception of your request, and we will notify you in writing the result of the cancellation practiced. You may request this cancellation by contacting us, indicating what data you refer to. You also have the right of opposition, at any time, which implies that you can object to the continuation of your personal data in Insulcloud contacting us, for which it must also be conveniently identified, in the same terms as for the exercise of previous rights. In no more than 10 days, we will stop processing your data unless there are legitimate and legal reasons that make the treatment we make about your data prevail over your interests, rights and freedoms, or for the formulation, exercise or defense of claims. The RGPD also gives you the right to data portability by which you can request a copy of your personal data in electronic format so that you can transmit such data for use in the service of a third party. We will comply with the exercise of this right without undue delay and as soon as possible, in response to technical needs. You also have the right not to be subject to automated decision-making, which includes the creation of profiles, when the decision may have a legal effect on you or produce a similar important effect. In the event that these rights are to be exercised with respect to the personal data of a minor, in addition to the previous proofs of identity, your request must be accompanied by a photocopy of the family book or document that proves that you are the legal representative of the minor, his/her parents or legal guardians. We also inform you that if for any reason you are not satisfied with the way in which Insulcloud we treat the information that we have under our responsibility with your personal data, you have the right to claim before the National Control Authorities: Germany, Austria, Belgic, Bulgaria, Cyprus, Croatia, Denmark, Slovakia, Slovenia, Spain, Estonia, Finland, France, Grecia, Hungary, Ireland, Italy, Latvia, Lithuania, Luxemburg, Malt, Netherlands, Poland, Portugal, United Kingdom, Czech Republic, Rumania, Sweden, Iceland, Liechtenstein, Norway, Switzerland If you wish to submit any kind of request regarding personal information that Insulcloud has about you, please do not hesitate to contact our Data Protection Officer, who will contact you as soon as possible.