This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with us.

WHAT INFORMATION WE COLLECT ABOUT YOU
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

ACCOUNT AND PROFILE INFORMATION
We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services. The Application collects only the data, which the user provides via the application User Interface and keeps it in the internal device memory and if the user is registered, on the secure server.

  • Email address, Username, First and Last name, Birthdate, Gender
  • Password (encrypted, not readable by us)
  • When using the Diabetes:M app: Device ID, manufacturer, device type, operating system version, locale, browser(web app)
  • Language, country, time zone
  • Registration date
  • Status of consents

The application doesn’t collect any personal information from the device where it is installed without user permission.

RELEVANT INFORMATION WE COLLECT

PERSONAL DATA

first name, last name, address, date of birth/age, gender, telephone number.

MEDICAL DATA

diabetes type, diagnosis year, insulin therapy (pen/pump/medications), blood glucose target range, height, weight, meter/therapy device, medications, type of insulin, basal settings, correction factors, carbs / insulin ratio.

COMMERCIAL AND USAGE DATA
App store download, purchase, invoices, payment status, payment method (google play/app store) promo codes used, IP address, device ID, operating system, browser type and version.

MEDICAL DATA
App entries such as date/time/time zone, type and duration of activities, food intake/meal/ingredients, pills taken/injections, blood glucose measurements, notes, blood pressure, weight, HbA1c, ketones, laboratory ata, images/photos, imported values; sensor data such as start date/time, end date/time, time zone, sensor value; temporary basal rate, date; app settings such as display options, activated integrations.

LOCATION
We only track the location of your device for the purposes of our “Smart Assistant” service with your explicit consent. We do not save the location on our servers.

THERAPY DEVICES
Devices as blood glucose meters can be paired with your device which enables data to be transferred to our apps.

HEALTH APPS
Health apps such as those by Apple, and other connected services also enable data to be exchanged with our apps. But synchronization only takes place if you activate this in the settings of our apps, namely, if you use the function.

OTHER INFORMATION WE COLLECT
Content you provide through our websites:The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.

Information you provide through our support channels:The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

HOW WE USE INFORMATION WE COLLECT
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.

We collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:

  • We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.
  • If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

HOW WE SHARE THE INFORMATION
The medical information can be shared anonymously and used for research and statistical analysis.

This means that all information containing personal identification will be omitted and WILL NOT BE SHARED, which includes, but not limited to any notes, comments, images and all textual information entered by the user.

For research purposes, information like diabetes type, selected therapy, gender, country and age might be shared along with the other values.

GOOGLE ANALYTICS AND ADVERTISING
We work with Google Analytics to help us understand how the Application is being used, such as the frequency and duration of usage. We work with advertisers and third party advertising networks like AdMob, who need to know how you interact with advertising provided in the Application which helps us keep the cost of the Application low. Advertisers and advertising networks use some of the information collected by the Application, including, but not limited to, the unique identification ID. We may also share anonymously via Google APIs your gender and age for advertising related use.

For more details about Google Analytics please visit Google Analytics

For Google’s Privacy Policy please visit Google Privacy Policy

If you’d like to opt-out from third party use of this type of information to help serve targeted advertising, please visit the section entitled Opt-out the targeted advertising below.

OPT-OUT THE TARGETED ADVERTISING
There are multiple opt-out options for users of this Application:

OPT-OUT OF ALL INFORMATION COLLECTION BY UNINSTALLING THE APPLICATION

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

OPT-OUT FROM THE USE OF INFORMATION TO SERVE TARGETED ADVERTISING BY ADVERTISERS AND/OR THIRD-PARTY NETWORK ADVERTISERS

You may at any time opt-out from further allowing us to have access to your location data by accessing this link http://www.google.com/ads/preferences/.

NAME AND ADDRESS OF THE RESPONSIBLE ENTITY
Diabetes:M is a property of and operated by Sirma Medical Systems AD. Responsible entity for the purposes of data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

SIRMA MEDICAL SYSTEMS AD
135 Tsarigradsko Shosse, fl.3
1784 Sofia, Bulgaria
Telephone: +35929768310
Email: info@sirma-medical.com
Website: www.sirma-medical.com

DATA PROTECTION OFFICER
Our data protection officer is available to answer all data protection questions at privacy@diabetes-m.com. The data protection officer monitors ‒ independently and not bound by instructions ‒ compliance with all data protection regulations and is subject to strict statutory secrecy and confidentiality obligations.

YOUR RIGHTS

REVOCATION OF CONSENTS

If we process your User Data based on your consent, you may revoke the consent at any time. However, this will not affect the lawfulness of the processing before the revocation. We will continue to provide our services if they do not depend on the consent that has been revoked.

INFORMATION, CORRECTION, AND RESTRICTION

Each user has the right to request information on the processing of their personal data. To do so, please contact us at any time at privacy@diabetes-m.com.

DELETION (“RIGHT TO BE FORGOTTEN”)

Each user has the right to request the deletion of their personal data. To do so, please contact us at any time at support@diabetes-m.com.

Last modified: 2019/06/05

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