Onduo LLC- Online Privacy Policy

Introduction

Onduo LLC ("Onduo") aims to bring the best, most up-to-date care to people with diabetes anywhere, anytime by developing comprehensive solutions that combine devices, software, medicine and professional care to enable simple and intelligent disease management, helping patients and members of their care team better understand, coordinate and manage the care process. Onduo respects the privacy of every individual and has taken extensive precautions to create a process that maintains individual privacy.

• We are committed to providing a secure environment for our services.
• We use the information provided to us to enable your use of our services, provide you with customer service, and authenticate your website visits and usage.
• All information you provide to us is kept on a secure server.
• We do not sell, lease, or rent personal information without your explicit consent.

This privacy policy is designed to inform users of Onduo and its platform (collectively, the "Service") about how we gather and use personal information collected by us in connection with use of the Service. We will take reasonable steps to protect user privacy consistent with the guidelines set forth in this policy and with applicable U.S. state and federal laws. WE TAKE THESE PRECAUTIONS IN AN EFFORT TO PROTECT YOUR INFORMATION AGAINST SECURITY BREACHES. HOWEVER, THIS IS NOT A GUARANTEE THAT SUCH INFORMATION MAY NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF SUCH FIREWALLS AND SECURE SERVER SOFTWARE. BY USING OUR SITE, YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND AGREE TO ASSUME THESE RISKS.

In this policy, "user" or "you" means any individual or enterprise using the Service, whether as the customer purchasing the Service or an authorized user of the Service. This Privacy Policy forms part of our Terms of Service.

BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE SERVICE.

What Information Do We Collect?

Limited Personal Information: We collect the following personal information about you in connection with the Service: (a) when you register to use the Service, we will collect your username and password; (b) if you pay your fees by credit card, we (or a third party payment processor acting on our behalf) will collect the name, expiration date and credit card number for the relevant card; and (c) if you communicate with us by email but do not otherwise register to use the Service, we will collect your email address. All of this information is referred to in this Policy as "Personal Information".

Use of Anonymous Information. We may use Anonymous Information (as defined below), or disclose it to third party service providers, to provide and improve the Service. "Anonymous Information" means information which does not enable identification of an individual user, such as aggregated information about use of the Service.

Web Tracking Information: We, and our third party service providers, may use web tracking technologies such as cookies, pixel tags and clear GIFs in order to operate the Service efficiently and to collect data related to usage of the Service. Such collected data ("Web Tracking Information") may include the address of the websites you visited before and after you visited the Service, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Service you visit and what links you clicked on, and whether you opened email communications we send to you. In order to collect Web Tracking Information and to make your use of the Service more efficient, we may store cookies on your computer. We may also use web tracking technologies that are placed in web pages on the Service or in email communications to collect information about actions that users take when they interact with the Service or such email communications, and Onduo’s Contractors (as hereinafter defined) may also do so. We do not correlate Web Tracking Information to individual user Personal Information. Some Web Tracking Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Service, but this may affect the performance of the Service.

• Log Files. When users visit our website, Onduo gathers certain information automatically and stores it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider, referring/exit pages, operating system, and date/time stamp. We use this information to monitor the usage of our site. Also, when we send e-mails to you, we may be able to identify information about your email address, such as whether you can read graphic-rich HTML emails. We use this information not to identify individual users, but to analyze trends, administer the site, track users' movements around the site, and gather demographic information about our user base as a whole which provides us with the ability to determine aggregate information about our user base and usage patterns. We may, in some circumstances, need to review this automatically collected data in combination with specific Registration Information to identify and resolve issues for individual users.
• Cookies. The Onduo website also uses cookies to enhance the browsing experience on the Onduo site. A cookie is a small text file or record that is stored on a user's computer when you visit our website, which collects information about your activities on the Onduo site. The cookies transmit this information back to the computers at Onduo or our third-party distributors of banners and newsletters; these computers are, generally speaking, the only computers which are authorized to read such information. The information captured makes it possible for us to: (i) speed navigation, and provide you with custom tailored content; (ii) remember information you give to us, so you don’t have to reenter it each time you visit the Onduo site; (iii) monitor the effectiveness of our marketing campaigns; and (iv) monitor total number of visitors, pages viewed, and the total number of banners served.
  • You can choose to have your browser warn you every time a cookie is being sent to you or you can turn off cookie placement. Also, by not using cookies, your overall internet browsing experience will be affected.
  • If you would like to obtain more information about the third-party distribution of banners on the Onduo site and to know your choices about having such cookies turned off, please visit www.privacychoices.org.
  • User Data: "User Data" is that data -- other than Personal Information -- that caregivers provide us regarding or related to themselves and the person who is receiving care. As described in the Terms of Service, we store User Data in order to provide the Service. We may also correlate User Data with third party data in order to provide the Service. If User Data includes any personally identifiable information or Protected Health Information, we will collect, store, use and disclose that information in the same way that we collect, store and use any of User Data.

How Do We Use the Information We Collect?

Personal Information: We will use and store your Personal Information for the purpose of delivering the Service, and to analyze and enhance the operation of the Service. We may also use your Personal Information for the internal operational and administrative purposes of the Service.

Web Tracking Information: We use Web Tracking Information to administer the Service and to understand how well our Service is working, to store your user preferences, and to develop statistical information on usage of the Services. This allows us to determine which features visitors like best to help us improve our Service, to personalize your user experience, and to measure overall effectiveness.

Aggregate and De-Identified Information: We will also create statistical, aggregated and/or de-identified data relating to our users and the Service for analytical purposes. Aggregated and/or de-identified data is derived from Personal Information and User Data but in its aggregated and/or de-identified form, it does not duplicate or reveal any User Data or relate to or identify any individual. This data is used to understand our customer base and to develop, improve and market our services.

Customer Testimonials: We may post customer testimonials on our web site, and may use testimonials in other formats consistent with consent received. Customer testimonials may contain personally identifiable information. We may use your Personal Information to contact you to obtain a testimonial and obtain your consent via email or agreement sent via fax, pdf or mail prior to using such testimonial and/or using your name along with your testimonial.

Legal Exception: Notwithstanding the above, we may in any event store and use Personal Information and User Data to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Privacy Policy and the Terms of Service) with you, or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.

Email Communications: If you register and provide your email address, we will send you administrative and promotional emails. If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email, or by editing your account settings as described below. All users receive administrative emails, and so you cannot opt out of them while you remain registered.

What Information Do We Disclose to Third Parties?

Personal Information and User Data: We will not disclose your Personal Information or User Data to any third parties except as follows:

(i) to third party contractors engaged to provide services on our behalf ("Contractors"), such as performing marketing, analyzing data and usage of the Service, hosting and operating the Service or providing support and maintenance services for the Service, or providing customer service. We enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us.

(ii) when we have your consent to share the information.

Web Tracking Information: We disclose Web Tracking Information to Contractors, in order to analyze the performance of the Service and the behavior of users, and to operate and improve the Service.

Aggregate Information: We may disclose aggregated data that does not contain Personal Information or User Data to any third parties, such as potential customers, business partners, and funding sources, in order to describe our business and operations.

Network Operators: Use of the Service may involve use of the services of third party telecommunications carriers. Such carriers are not our contractors, and any information that a carrier collects in connection with your use of the Service is not "Personal Information" and is not subject to this Privacy Policy. We are not responsible for the acts or omissions of telecommunications carriers.

Additional Disclosures: We reserve the right to disclose any information we collect in connection with the Service, including Personal Information, to: (a) any successor to our business as a result of any merger, acquisition, asset sale or similar transaction; and (b) any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights or to protect third parties.

Third-Party Service Providers; Additional Terms

As described in the related Onduo Terms of Use, Onduo relies on services from Verily Life Sciences LLC ("Verily") to deliver certain components of the Onduo Platform, which may include the smartphone application and/or web-based coach console, provided by Onduo in conjunction with the Onduo Platform. In addition to this Onduo Online Privacy Policy, your use of such components of the Onduo Platform is subject to the Verily Privacy Policy set forth at https://verily.com/privacy-policy/.

Privacy Settings/Opt Out

If you would like your name and email address permanently removed from our database, please contact us at privacy@Onduo.com. We will promptly delete your name and email address and you will no longer receive email from Onduo. Your removal from the mailing list or database will not remove data you have submitted to us or records of past use of the Service, nor delete information stored in our data backups and archives. Such data will be maintained and/or deleted in the ordinary course of Onduo's business.

California Online Privacy Protection Act Notice

On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like us to disclose how we respond to "Do Not Track Signals"; and whether third parties collect personally identifiable information about users when they visit us.

(1) We do not track users who do not interact with our sharing functionality across the web, and therefore do not use "do not track" signals.

(2) We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies without separate member consent.

California Civil Code Section 1798.83 also permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@Onduo.com. Please note that we are only required to respond to one request per customer each year.

General

Security: We use reasonable security precautions to protect the security and integrity of your Personal Information in accordance with this policy and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur.

Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

Links: The Onduo Service may contain links to other websites. Onduo is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our Service and review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by the Service. We encourage our users to read the privacy policies of these other web sites before proceeding to use them.

Amendments: Onduo may modify or amend this policy from time to time. If we make any material changes, as determined by Onduo, in the way in which Personal Information is collected, used or transferred, we will notify you of these changes by email and by posting a modified version of this Privacy Policy on our website. Notwithstanding any modifications we may make, any Personal Information collected by Onduo from you will be treated in accordance with the privacy policy in effect at the time information was collected, unless we obtain your consent otherwise.

Children: Onduo does not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the Service is directed at persons under 18. If you are under 18 years of age, then please do not use the Service. If Onduo learns that personally identifiable information of persons less than 13 years of age has been collected without verifiable parental consent, then Onduo will take the appropriate steps to delete this information. To make such a request, please contact us at privacy@onduo.com.

Service Visitors from outside the United States: Onduo and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access or use the Service, you consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.

Effective Date of this policy: December 13, 2017

Last updated: December 13, 2017