WELCOME

Welcome to our privacy policy and terms and conditions. The security of your personal data is important to us and we want you to have complete clarity about what we do (and don’t do) with your personal data. We are MySugarWatch^® Ltd (“we”, “us” and “our”) and we are committed to protecting and respecting your privacy.

This policy sets out the basis on which we may collect personal data from you through your use of this website, including any data you may provide when you register your interest in or subscribe to MySugarWatch^®® Data Services. It explains what personal data (including medical data) we collect, why we collect it and what we do with it.

It is important that you read this privacy policy together with any other privacy or fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy policy covers:

• Important information and who we are
• The data we collect about you
• How we use your data
• Disclosure of your information
• Where we store your information
• Security of your information
• How long we store your information
• Your rights
• Our cookie policy

IMPORTANT INFORMATION AND WHO WE ARE

Who we are

For the purpose of applicable data protection law, the controller or data controller (as applicable) is MySugarWatch^® Ltd (registered in Jersey with company number 115335) of Lande a Geon, Le Vieux Beaumont, St Peter Jersey JE3 7EA. Our registration number with the Information Commissioner’s Office in the UK (“ICO”) is ZA901082 and our registration number with the Jersey Office of the Information Commissioner (“JOIC”) is 65043. The “applicable data protection law” means the Data Protection Act 2018, the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) known as the UK GDPR, and the Data Protection (Jersey) Law 2005.

How to contact us

If you have any questions about this privacy policy or our privacy practices, please contact us by email at info@mysugarwatch.com.

Changes to the privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Your duty to keep us informed

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

This website may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms and conditions of use and that we do not accept any responsibility or liability for these policies on your use of these websites. Please check these policies before you submit any personal data to these websites.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in Table 1 and Table 2 below, along with the various methods used to collect this data. We also collect certain information about your health, known as a “Special Category of Personal Data” which includes medical data.

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your medical data (meaning you cannot be personally identified from it) for:

• research into the incidence and paths of diabetes;
• creating health reports and statistics for medical research bodies and pharmaceutical companies in the field of diabetes;
• the ongoing monitoring and improvement of current and future diabetic treatment and management.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

HOW WE USE YOUR DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we have your consent.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party, e.g. a social care organisation) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Depending on the specific purpose for which we are using your data, we may process your personal data for more than one of the above lawful grounds.

Table 1: NON MEDICAL DATA
What we collect and where it comes from		Why we collect it	Retention Period
While using the MySugarWatch® mobile app you will be requested to allow the app permission to access your location even when the app is running in the background.	This is required to allow the MySugarWatch® mobile app to maintain a Bluetooth connection to the MySugarWatch® transmitter while the app is in the background to avoid missing those important glucose alerts.			This information is not retained.
We will collect your name, date of birth and e-mail address when you submit them to us when registering your interest in MySugarWatch®® Data Services.		To provide you with information and keep you updated on the launch of MySugarWatch®® Data Services. To assign you a “Pole Position Reference Number” which you may benefit from if you choose to register for MySugarWatch®® Data Services upon launch.	10 years from the date of collection (or sooner if you ask us to erase your data).
We will collect your name, date of birth, e-mail address, postal address, when you submit them to us when subscribing to MySugarWatch®® Data Services.		To register you as a new subscriber. To process and deal with your subscription and to deliver products to you as part of your subscription. To manage your subscription. To communicate with you about our products and services.	10 years from the date of collection (or sooner if you ask us to erase your data).
If you correspond with us via email, phone, letter or other media, we will keep a record of that correspondence and the data within it.		To communicate with you about our products and services.	10 years from the date of collection (or sooner if you ask us to erase your data).
We collect standard technical information when you access and use this website, including: your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.		To administer and protect this website. To use data analytics to improve this website and the experience of visitors.	10 years from the date of collection (or sooner if you ask us to erase your data).
We collect usage data when you access and use this website, including: the full URL clickstream to, through and from website (including date and time), length of visits, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from this website.		To administer and protect this website. To use data analytics to improve this website and the experience of visitors.	See cookie policy below.

Table 2: MEDICAL DATA
What we collect and where it comes from	Why we collect it	Retention Period
When you register your interest in receiving pre-launch updates about MySugarWatch®® Data Services Data: Diabetes type,  blood pressure, height, weight, your current medications and their treatment regime	To monitor the level of pre-launch interest in MySugarWatch®® Data Services	10 years from the date of collection (or sooner if you ask us to erase your data).
When you subscribe to MySugarWatch®® Data Services Data: Diabetes type, blood pressure, height, weight, your current medications and treatment regime	To deliver MySugarWatch®® Data Services	10 years from the date of collection (or sooner if you ask us to erase your data).
As a subscriber, through your use of MySugarWatch®® Data Services, we will collect data on an ongoing basis. Data: The data above, as well as,  blood glucose levels, fluctuations in those levels and time spent at particular blood sugar levels, times and dates on which you take your current medication, mealtimes and your typical sleeping or resting behaviour.	To deliver MySugarWatch®® Data Services	10 years from the date of collection (or sooner if you ask us to erase your data).

Marketing

We will from time to time provide you with marketing communications, and by registering your interest in the launch of MySugarWatch^®® Data Services, you consent to us sending marketing information to you. You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Cookies

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good browsing experience and also allows us to improve our website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy below.

DISCLOSURE OF YOUR INFORMATION

We may share your personal information (including medical data and non-medical data) with the following types of recipients, but any such sharing will be carried out as part of our routine business operations:

• our service providers acting as processors based in Jersey and the United Kingdom who provide IT support, system administration, cloud services, maintenance services, CRM services and email services only;
• certain third parties with whom you expressly request us to share your personal data, through your use of MySugarWatch^®® Data Services;
• any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 / the Companies (Jersey) Law 1991;

We also want to make you aware that, if a third party acquires MySugarWatch^® Ltd or substantially all of its assets, or if we acquire a third party, the personal data held about users and subscribers will be one of the transferred assets. An acquirer of MySugarWatch^® Ltd will be obliged to comply with the terms of this privacy policy.

We may also disclose your personal data if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if such sharing or disclosure of your personal data is required in order to enforce a legal agreement between us or to protect the rights, property, or safety of MySugarWatch^® Ltd, our customers, or others.

Except as provided in this privacy policy, we will not share your personal information with any third parties.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you will be transferred to and stored in Jersey, which is deemed to provide an adequate level of protection for personal data by the United Kingdom and European Union. It will also be processed by our staff operating in Jersey or by our distributors, and is also backed-up in the UK. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. If we give you (or where you have chosen) a password which enables you to access certain parts of this website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

The transmission of information via the internet is not completely secure, and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to this website. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

SECURITY OF YOUR INFORMATION

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WE STORE YOUR INFORMATION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are set out in Table 1 and Table 2 above.

In some circumstances we will aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information without further notice to you.

YOUR RIGHTS

You have rights under data protection laws in relation to your personal data, including the right to:

• request access to your personal data.
• request correction of your personal data.
• request erasure of your personal data.
• object to processing of your personal data.
• request restriction of processing your personal data.
• request transfer of your personal data.
• withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You always have the right to make a complaint at any time to the ICO (www.ico.org.uk) or JOIC (www.jerseyoic.org) for data protection issues.  We would, however, appreciate the chance to deal with your concerns before you approach them so please contact us in the first instance.

No fee usually required. Note that MySugarWatch^®® Data Services is a paid for service, although you will not usually have to pay a fee to exercise access to your personal or medical data.  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

COOKIE POLICY

This website uses cookies to distinguish you from other users. This helps to offer you a more tailored experience when you browse our website and also allows us to improve the website.

What are cookies?

A cookie is a small file of letters and numbers that we store on your browser or your device (such as your computer, tablet or mobile phone) if you agree. Cookies contain information that is transferred to your device. For more information, please see www.allaboutcookies.org.

What types of cookies do we use?

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. All of the information collected by these cookies is anonymous and is only used for statistical purposes.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title Cookie Name	Purpose	More information
Google Analytics (_ga)	This is used to distinguish unique users of the website. By default it is set to expire after 2 years	See here
Google Ads (_gac_<property-id>)	This contains campaign related information for a user and is used to help you track sales and other conversions from our ads. It will expire after 90 days.	See here

Other tracking technology

This website may contain a web beacon to track whether you click on any links. [Add further information about any such use].

How can I manage or disable cookies?

You can disable cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to disable all cookies you may not be able to access all or parts of this website or certain features of it.

Date of Preparation: February 2021
POL-002/V2