INTELLIGO PRIVACY POLICY
THIS PRIVACY POLICY ARE EFFECTIVE AS OF November 20, 2020.
These Privacy Policy is between Intelligo (“Intelligo”,“we” or “us”) and you or any other person for whose use and on whose behalf you purchase a Intelligo Product or service（“you”）, concerning your use of (including any access to): the Intelligo website located at www.intelligofree.com; the software applications we make available for download or access at our Websites, in the Google Play, App Store or Huawei AppGallery or other mobile service provider locations or other locations we indicate (“Apps”); and any Intelligo products (“IntelligoProducts” ) and our data services available through the internet to users of Intelligo Products or Software Apps that provide and permit the access, collection, storage, processing, analysis and/or transmission of data generated by a Intelligo Product or Software App ("Intelligo Services"); as well as any email or other messages that you receive from us.
We are commited to protecting your personal information and your right to privacy. If you have any questions and concerns about this privacy notice, or our pratices with regards to your personal information, please contact us at info@intelligofree.com.
When you and more generally, use any of our Intelligo Websites, Products, and Services, we appreciiate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there is any terms in this privacy notice that you do not agree with, please discontinue use of Intelligo Websites, Products and Services.
This privacy notice applies to all information collected through Intelligo Websites, Products and Services, as well as any related services, sales, marketing or events.
Intelligo Data Service
Our Data Service, included in Intelligo Services, is intended to allow a user to use the data generated by, or created in connection with the use of Intelligo to help the user to manage his or her diabetes in accordance with the applicable labeling of Intelligo Websites, Products and Services.
Each Data Service or software app may require the creation of an Intelligo user account on the software app. If so, you are required to accurately complete and maintain the user account and to provide us with all required information. You are responsible for obtaining, maintaining and paying for all hardware, software and telecommunications and other services necessary for the use of the data services.
Use of our Data Services requires an internet-enabled smart device or computer. Each Data Service receives user data from a software app that is downloaded to your smart device or computer.
Our Data Services may also permit users to share user data, reports and other information relating to the user to certain third parties selected by the user. By selecting the third party (which may be a person, a software app, or another business), you are authorizing us to send your user data to each party you select. Intelligo does not verify or validate any information regarding such third parties or the information you have provided regarding them. Once your information has been provided to a third party designated by you, Intelligo has no further control or responsibility regarding that information.
Our collection, storage and transmission of user data and any other information that you provide to Intelligo through Intelligo Websites, Products and Services are governed by the Privacy Policy.
What information do we collect?
We only collect personal information that you provide to us.
The personal data we receive from you (which we refer to collectively as your "Personal Information") includes but not limited to Registration and Ordering Information, Feedback Information, Data Services Information, User Information and Derived Information, such as glucose readings, information associated with each glucose reading, date, time, and device identifier; Thresholds input into Data Services or Software Apps and notifications arising from those thresholds.
In general, you are entitled to at any time access your Personal Information. You have the right to request rectifying, erasing, transferring some of this information to other organizations or restricting its processing. You may also have rights to object to some processing and, where we have asked for your consent to process your data, to withdraw this consent.
By clicking "accept" to this Privacy Policy, you agreed that Intelligo has the right to collect and use Data Services Information, store it on our servers, process it using Data Services, and transmit it to the User and each Designated Recipient and Designated Third Party Service, where applicable for Intelligo Websites, Products and Services that are requested by you.
By clicking "accept" to this Privacy Policy, you agreed that Intelligo has the right to use Data Services Information in connection with our provision of Data Services and for our operations, administration and product development, maintenance and support in line with applicable data protection laws.
How your information is used?
We may use your Personal information to carry out our obligations arising from any contract entered by you and us, including:
Registration and Ordering Information to manage your account and Intelligo Products and Services applicable to you. We also use your email address to contact you regarding your account. We make any Registration and Ordering Information confidential;
Feedback Information you are provide to us. We do not identify you or include any information that could be used to identify you. Feedback Information may be used by us and provided by us to our customers and third parties;
Data Service in connection with our provision of Data Services and for our operations, administration and product development, maintenance and support in line with applicable data protection laws;
Analytical statistics to improve our products and provide better service tailored to you. We may use Personal Information (anonymous) in accordance with applicable data privacy laws to manage our Products and Services, including the Website, to improve our business and provaide new website and product and service features, and to otherwise manage our business;
Law Enforcement and Legal Proceedings required by applicable law, including laws outside your country of residence, to prevent fraud, abuse, illegal uses and violations of our Terms of Use. We may use and disclose Personal Information to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; to protect our operations or those of any of our affiliates; to enforce this Privacy Policy; and to allow us to pursue available remedies or limit the damages that we may sustain; in each case in accordance with applicable data protection laws;
De-Identification as removing information that could identify you, and we may use such de-identified information for any purpose, except where we are required to do otherwise under applicable law;
Other Uses for purposes other than those permitted in this Privacy Policy but only after you consent to such use.
We will only use your data with your consent to provide services to you. We will only collect and keep glucose monitoring history (readings, calibrations, alerts) for you to access. With consent you can share information with others. You have the right not to upload device data to the Intelligo servers, in which case data will not be accessible to others. Without the data upload the only record of information is on your smart device itself.
Will your information be shared with others?
We only share information with your consent, to comply with law, to provide you with services, to protect your rights, or to fulfill business obligations.
We may hold, process, share and transfer your Personal Information but solely for legitimate purposes in accordance with applicable laws, ordinances and guidelines, and it is only disclosed on a need-to-know basis to those who are authorized to use it for these purposes.
We do NOT share or transfer your information in connection with, or during negotiation of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.
We do NOT share your information with our affiliates. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
We do NOT share your information with our business partners without your consent.
Third Parties
In the ordinary course of our business, Intelligo will collect and use providers to perform services or functions on our behalf. We will not authorize those third parties to keep, use or disclose your Personal Information except for providing the services we have asked them to provide.
When you elect to share your protected health information with a Designated Third-Party Service, such as through the Apple Health app, you are electing to provide your data to a third party, and your authorization continues until you revoke it.
Your Designated Recipients may share your Personal Information with Intelligo for purposes relating to their use of Intelligo Websites, Products and Services.
Once you share any Personal Information with a third party, including Designated Third-Party Services, we have no control over that Personal Information and how it is used by any such third party. You should refer to the terms of service, privacy policy and other provisions of the websites for each third party to which you provide any Personal Information yourself, and for any Designated Third-Party Service you authorize.
Is your Information transferred Internationally?
In compliance with GDPR (General Data Protection Regulation), our major servers are located in Frankfurt, Germany.
As part of the services offered to you, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. By submitting your personal data, you’re agreeing to this transfer, storing or processing.
If you are a resident out of EU, we only store your personal information in our servers, your personal information will only be transferred with your consent, to comply with law, to provide you with services, to protect your rights, or to fulfill business obligations.
If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If you use our services while you are outside the EU, your information may be transferred outside the EU to provide you with those services.
We take reasonable steps to protect all personal information from loss, misuse, and unauthorized access, disclosure, alteration or destruction. You should however keep in mind that no internet transmission is ever 100% secure or error free. And you should therefore take exceptional care in deciding what information you send to us via e-mail and avoid including any of your personal or healthcare information without encrypting it first and we would ask you not to share your passwords with anyone.
How long do we keep your information?
Your data is stored in Intelligo Products for 90 days, data transferred to Intelligo Products is stored offline on your smart device.
We keep your information/data you upload in the servers for 2 years.
We are required under law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after your last transaction with Intelligo, after this time they will be destroyed.
We securely store your personal information and isolate it from any further processing until deletion is possible.
Do we collect information from minors?
We are concerned to protect the privacy of children, children aged 16 or under must have parent/guardian's consent before we will accept any personal information.
Applicable laws and regulations
For Personal Information that Intelligo receives from users, affiliates and companies in the European Union, the European Economic Area, and Switzerland, Intelligo will commit to handling such personal information in accordance with General Data Protection Regulations (GDPR) and the European law principles for international transfers such as EU Standard Contractual Clauses or Privacy Shield.
Where Intelligo requires your Personal Information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage the relationship, or to meet obligations placed on us. In all other cases, provision of requested Personal Information is optional.
What security measures do we take to protect your personal information?
Each user will need an Intelligo account and a password to access the data in any of Intelligo Websites, Products and Services. All of our systems are protected by strong passwords, a firewall to filter any malicious access, intrusion detection to detect any system anomalies and malicious code protection to perform security checks on all committed data.
In order to ensure the confidentiality of your data different types of user have different access levels, you own your healthcare data, you can upload, download or delete it, you can choose to share it with others which will give them the ability to view or download your data.
We use a firewall to filter any malicious access, intrusion detection to detect any system anomalies and Malicious code protection to perform security checks on all committed data.
Data encryption: AES symmetric encryption is used to encrypt and store important information such as user names, email addresses, and mobile phone numbers.
Database attack prevention: The complexity of the account password prevents hackers from hitting the database. We also change the default port to prevent hacking.
Interface security: Strictly restrict the user's menu authority + button authority, and only return the user's matching authority data
Data encryption: The CGM glucose data stored and transmitted via hardware is data encrypted.
Further Processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection privacy notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Your rights with your personal information
Contact our Data Proetction Officer at info@intelligofree.com for any requests.
Based on the applicable laws of your country, you have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. You are able to review, update or delete your personal information at any time using your own access to Intelligo Websites, Products and Services or by contacting us.
You have rights to object to some processing and, where we have asked for your consent to process your data, to withdraw this consent. These rights may be limited in some situations – for example, where fulfilling your request would reveal Personal Information about another person or where we can demonstrate that we have a legal requirement to process your data.
You have the right to request your personal data is erased where it is no longer necessary for Intelligo to retain such data.
You have the right to request that Intelligo provides you with your personal data and where possible, to transmit that data directly to another data controller, this applies where the processing is based on your consent or is necessary for the performance of a contract with you by automated means.
You have the right to lodge a complaint with the Information Commissioners Office:
Keizersgracht 421, 1016EA Amsterdam, Netherlands
Do we make updates to this Privacy Policy?
We may update this privacy notice from time to time. The updated version will be indicated by an updated date and will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
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