Putting you first – ViCentra’s privacy statement

Your privacy is important to us. We know that is what all privacy statements say but we mean it. Putting people first is one of our most important principles – we treat others as we want to be treated and look out for each other. That includes protecting and ensuring you have control over your own personal data.

This statement explains how we collect, transfer, process, use, disclose and look after any personal data you give us (regardless of where you are from, or how you provide it). This statement also informs you on our security practices, your privacy rights (including how you can get access to your personal data) and how the law protects you.

For your convenience, we have added a list of useful terms and definitions (Glossary) at the end of this document.

It is important to add that we might need to update this statement from time to time. As such it is good to check our website from time to time to read and understand this statement. It is equally important that the personal data we retain about you is accurate and up to date. As such we ask that you keep us informed if your personal data changes during your relationship with us.

This privacy statement supplements any other privacy notices we give you and is not intended to overwrite them.

 

Contents

  1. About us

1.1 Who are we?

1.2 Contact details

  1. Your data

2.1 What type of data do we collect about you?

2.1.1 Definition of personal data

2.1.2 Type of data we collect about you

2.1.3 Lawful basis to collect your data

2.2. If you don’t want to provide personal data.

2.3.       How is your personal data collected?

2.4 Disclosures of your personal data

2.5 International transfers

2.6 Data security & Integrity

2.7 Data retention

  1. Marketing

3.1. Promotional offers from us

3.2. Third-party marketing

3.3. Opting out

3.4. Our website

3.4.1. Cookies

3.4.2. Third-party links

  1. Your legal rights

4.1. List of your legal rights

4.2. No fee usually required

4.3. What we may need from you

4.4. Time limit to respond

Glossary

LAWFUL BASIS

THIRD PARTIES

YOUR LEGAL RIGHTS

 

1. About us

1.1 Who are we?

ViCentra B.V. is made up of different legal entities (“ViCentra Group”), see contact details below. This privacy statement is issued on behalf of the ViCentra Group so when we mention “ViCentra”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the ViCentra Group responsible for processing your data. ViCentra B.V. is the data controller, for all of its entities and will always guarantee compliance with the GDPR of its affiliates. ViCentra B.V. is also the controller responsible for the website.

1.2 Contact details

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy statement. If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact our DPO using the details set out below. We highlight that the DPO is bound by law to maintain confidentiality with regards to any questions and/or issues you may present.

Email address: dpo@vicentra.com

Postal address: ViCentra B.V. attn. DPO, Kanaalweg 17B2, 3526 KL Utrecht, The Netherlands.

2. Your data

2.1 What type of data do we collect about you?

2.1.1 Definition of personal data

According to Article 4 of the GDPR, ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

This definition does not include data from which the identity has been removed and cannot be related back anymore to a living person (anonymous data).

2.1.2 Type of data we collect about you

Depending on situations detailed in the lawful basis table below, the different types of data we might collect from you are the following:

  • Identity Data includes your first name, last name, username or similar identifier, title, date of birth, gender, social security information.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes health insurance information for payment purposes.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your 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.
  • Profile Data includes your username and password, purchases or orders made by you, your interests and preferences regarding our products and related marketing activities, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences (see Third-party marketing below).
  • Medical Data includes information about you that may identify you and relates to your past, current, or future health or condition and related health care provision regarding ViCentra’s or similar products.

We also collect, use and share Aggregated Data with third parties such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific product feature. 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.

We do not collect data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions or trade union membership. Nor do we collect any information about criminal convictions and offences.

2.1.3 Lawful basis to collect your data

The lawful basis table below is a detailed description of all the ways we plan to use your personal data, and which are the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Whenever you provide an explicit consent for any of the purposes and/or activities as set out below, we note that you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

We will only use your personal data when the law allows us to. With the exception of the disclosures outlined in this privacy statement we will obtain your written authorization before using your personal data or disclosing it to any third parties.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a potential customer.

•       Identity

•       Contact

•       Medical

Explicit consent
To register you as a new customer.

•       Identity

•       Contact

•       Medical

Performance of a contract as a Kaleido user
To process and deliver your order including:

 

 

(a) providing your tailored product and related services;

 

•       Identity

•       Contact

•       Medical

Performance of a contract as a Kaleido user
(b) Manage payments, fees and charges;

•       Identity

•       Contact

•       Financial

•       Transaction

Performance of a contract as a Kaleido user
(c) Collect and recover money owed to us;

•       Identity

•       Contact

•       Financial

•       Transaction

Performance of a contract as a Kaleido user
(d) Respond to your questions including troubleshooting and performance issues.

•       Identity

•       Contact

•       Medical

Performance of a contract as a Kaleido user
To exchange information with your healthcare professional about the prescription and usage of your Kaleido product.

•       Identity

•       Contact

•       Medical

Explicit consent

 

To manage our relationship with you and ensure quality of product and service which will include:
(a) Notification (e.g. product/supply reorder notifications, changes to our terms or privacy policy);

•       Identity

•       Contact

•       Communication

•       Medical

Performance of a contract as a Kaleido user

 

(b) Asking you to take a feedback survey

•       Identity

•       Contact

•       Marketing and Communications

•       Medical

Explicit consent
(c) Evaluate product and service quality, performance and usage.

•       Identity

•       Contact

•       Medical

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, to develop them and grow our business).

In case of disagreement, you can contact ViCentra at dpo@vicentra.com.

 

 

(d) to prepare and send you tailored marketing and communication information where you have consented for such communication;

•       Identity

•       Contact

•       Marketing and Communications

•       Medical

Explicit consent
(e) for process improvements and validation including software updates and security purposes;

•       Identity

•       Contact

•       Marketing and Communications

•       Medical

Performance of a contract as a Kaleido user
(f) for research and development, data/ statistical analysis purposes, new functionality, features and product development following established protocols to ensure the privacy of your Medical Data;

•       Identity

•       Contact

•       Profile

•       Marketing and Communications

•       Medical

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, to develop them and grow our business).

In case of disagreement, you can contact ViCentra at dpo@vicentra.com.

(g) Health Oversight/ Legal e.g. disclosure to government agency for health benefits processing or disclosure to report adverse events (or similar)/ product issues as required by law.

•       Identity

•       Contact

•       Profile

•       Marketing and Communications

•       Medical

Necessary to comply with a legal obligation

 

 

 

To administer and protect our business and this website (including troubleshooting, data analysis involving aggregated data, testing, system maintenance, support, reporting and hosting of data).

•       Identity

•       Contact

•       Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise).

In case of disagreement, you can contact ViCentra at dpo@vicentra.com.

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

•       Identity

•       Contact

•       Usage

•       Marketing and Communications

•       Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

In case of disagreement, you can contact ViCentra at dpo@vicentra.com.

To make suggestions and recommendations related to diabetes to you about goods or services that may be of interest to you

•       Identity

•       Contact

•       Technical

•       Usage

•       Communication  and marketing.

Explicit consent

 

2.2. If you don’t want to provide personal data

Where we need to collect personal data under the terms of a contract we have with you, and you don’t want to provide the data that is requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a product or service). In this case, we may have to cancel a product or service you have with us.

If this is the case we will notify this to you beforehand, before possibly having to end a possible contractual relation.

If we have to collect certain personal data about you by law (legal obligation), that you don’t want to provide to us, we might also not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a product or service). In this case, we may have to cancel a product or service you have with us.

2.3.         How is your personal data collected?

We use different methods to collect data from and about you through:

  • Direct interactions. You may give us your Identity, Contact, Financial and Medical Data by filling in forms or by contacting us by post, phone, email, social media, in person at a trade fair or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • provide your contact details via our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a promotion or survey; or
    • give us feedback.
  • Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from anonymized analytics providers such as Google based outside the EU (e.g. Google Analytics).
    • Contact, Financial, Transaction and Medical Data from our partner providers of technical, payment, delivery and healthcare services e.g. your health care provider (so we provide your tailored product and service), your data upload service provider (e.g. scanned medical data from Glooko Inc. formerly known as Diasend A.B. outside the EU), your health insurance provider (e.g. for a health insurance claim to collect payment) and our distributors, (such as OneMed for our Netherlands customers inside the E.U.) to deliver your product, provide customer service, product and process improvements.

2.4 Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2.1.3 above.

  • Internal Third Parties as set out in the Glossary at the end of this document.
  • External Third Parties as set out in the Glossary at the end of this document.
  • Third parties to whom we may choose to transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If such a change happens to our business, then the continuity of our business will require the new owners use your personal data in the same way as set out in this privacy policy. In such case we will inform you prior to this.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions based on proper processing agreements, including appropriate confidentiality clauses.

2.5 International transfers

We do not transfer your data outside of the European Economic Area (EEA).

2.6 Data security & Integrity

We have put in place industry standard, appropriate security measures to prevent your personal data from being lost, used or accessed in an unauthorized way, altered, disclosed or destroyed. We also work to ensure and maintain the accuracy and reliability of your personal data.

Throughout this privacy policy, we will explain  what data will be collected and used for, request your consent when and how required by law, and we will remind you of your rights. Additionally if we then want to use this personal data for an unrelated purpose we will inform you. In short, we will remain open and transparent throughout our relationship and once our relationship has ended.

We will only collect data that is adequate, relevant and limited to what is necessary for the intended purpose of the data collection. We also use security procedures and business systems to limit your personal data to those authorized employees, agents, contractors and other third parties who have a business need to know and who are bound by appropriate contractual arrangements. 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. If a personal data breach is likely to result in a high risk to your rights, we shall communicate the personal data breach to you without undue delay.

Additionally, components returned to us through the complaint process (e.g. broken Kaleido Handset), that might still be data carriers, will be subject to destruction by a specialized external supplier. Destruction certificates are delivered by the external supplier to ViCentra.

2.7 Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 unauthorized 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 requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting dpo@vicentra.com.

3. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

3.1. Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have explicitly consented to receive that marketing.

3.2. Third-party marketing

We will only share your personal data with companies outside of the ViCentra group of companies for marketing purposes after your explicit consent.

3.3. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

3.4. Our website

3.4.1. Cookies

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.

3.4.2. Third-party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

4. Your legal rights

4.1. List of your legal rights

You have rights under data protection laws in relation to your personal data:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it to your personal data.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This is known as the “right to be forgotten”. It enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note that this may not be possible for data that might be legally mandatory to keep. If applicable, we will inform you about this at the time of your request.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You have the right to lodge a complaint at any time to the following authorities:

Hopefully you will give us the chance to listen and address your concerns before you approach the authorities so if you have any concerns or queries, please contact us via dpo@vicentra.com.

 

4.2. No fee usually required

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

4.3. 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.

4.4. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

 

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or in order to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Explicit consent means not only consent which is given freely, specifically and on an informed basis but which is a very clear and specific statement of consent. Consent can be just as easily retracted.

THIRD PARTIES

Internal Third Parties

Other companies in the ViCentra Group than ViCentra B.V. acting as joint controllers or processors with ViCentra B.V. and who are based inside the EU.

External Third Parties

  • Service providers acting as processors (e.g. OneMed based in The Netherlands who provide distributor services);
  • Professional advisers acting as processors or joint controllers including bankers, auditors and insurers based inside the EU who provide consultancy, banking, insurance and accounting services.
  • Legal, regulatory and other authorities acting as processors or joint controllers based inside the EU who require reporting of processing activities in certain circumstances.
  • These processors shall all protect your rights and shall all act in such a manner that processing will meet the requirements of the law.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive an overview of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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