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Privacy Policy - APP

1. Identification and contact details of the data controller2. General information: description of the information contained in the privacy policy3. Necessary and updated information4. Exercising your rights5. Detailed information on the processing activities performed by service:6. Security7. Confidentiality8. Privacy policy updates9. Data transfers and international transfers

Last reviewed: july 2024

1. Identification and contact details of the data controller

Igluco Tech, S.L., a company with its registered office at Avenida República Argentina, 25, 8th floor (41011), Seville, is responsible for the processing of personal data handled through this mobile application "GLUCUBE APP" (hereinafter "the application" or "the app").

This privacy policy aims to provide information about the rights granted to the user of the application under the General Data Protection Regulation (GDPR) Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDDG), approved on December 5, 2018.

At Igluco Tech, protecting personal information, its security, and confidentiality is of the utmost importance. Therefore, we recommend that you read this Privacy Policy carefully, as the information you provide through this app is protected under the terms of this Privacy Policy. Additionally, we remind you that the use of this app implies acceptance of this Privacy Policy.

If you have any questions regarding the processing of your personal data, you can contact the Company at the following address: privacy@glucube.com.

2. General information: description of the information contained in the privacy policy

First, you should know that all operations, processes, and technical procedures carried out, whether automated or not, that enable the collection, storage, modification, transfer, and other actions involving personal data are considered personal data processing.

In this privacy policy, you will find information identifying the data processing carried out by Igluco Tech through this app. Specifically, you will be informed about:

  • The purposes of the processing of your personal data, i.e., the reason why Igluco Tech processes your personal data.
  • The legal bases that allow Igluco Tech to process your data for the indicated purpose.
  • The possible transfer or communication of your data to third parties and the reason for such communication. In this regard, we inform you that we do not transfer your personal data unless there is a legal obligation (Public Treasury, Judges and Courts, Security Forces, etc.) or as expressly indicated in the table below in the next section.
  • Furthermore, the data processors of the company, i.e., service providers who need access to your personal data to perform their functions, may access your personal data. The service providers who access your personal data are generally involved in information systems and technology. The table below indicates, where applicable, the sectors to which other possible service providers that may access your personal data belong.

Web hosting: Odoo

Marketing – CRM and digital marketing service: Hubspot

  • You can request more detailed information about the recipients of your data by sending an email to the following address: privacy@glucube.com.
  • The existence of potential international data transfers.
  • The data retention period for the data you provide. We inform you that, thereafter, your data will remain blocked for handling legal, administrative, or tax claims, for the periods legally determined by the applicable regulations.

3. Necessary and updated information

The fields we ask you to fill out in the forms provided in our app, whenever they contain asterisks, are mandatory, meaning that omitting any of them could prevent you from submitting your contact information and receiving the requested services. You must provide truthful and updated information.

When providing the data requested in the existing contact forms, you should not choose offensive, injurious, or misleading expressions or terms that coincide with trademarks, trade names, business signs, company names, advertising expressions, names or pseudonyms of public figures or celebrities, for which you are not authorized to use.

As a user, you accept and guarantee that the personal data you provide is truthful, being solely responsible for any damage or harm, direct or indirect, that may be caused to Igluco Tech as the responsible party for this application or to third parties if you complete any form with false data or data of third parties, causing deception, damage, or harm.

To ensure your information is always updated and error-free, you must notify Igluco Tech as soon as possible of any modifications or corrections to your personal data by sending an email to:  privacy@glucube.com.

4. Exercising your rights

We inform you that you can exercise the following rights:

  • Right of access to your personal data to know which data is being processed and the processing operations carried out with it.
  • Right to rectify any inaccurate personal data.
  • Right to delete your personal data.
  • Right to request the restriction of the processing of your personal data when the accuracy, legality, or necessity of the data processing is in doubt, in which case we may retain the data for the purpose of exercising or defending claims.
  • Right to object to the processing of your personal data when the legal basis for our processing is legitimate interest, as indicated in the table in section 5. Igluco Tech will stop processing your data unless there is a compelling legitimate interest or for the establishment, exercise, or defense of legal claims.
  • Right to data portability when the legal basis for our processing is consent, as indicated in the table in section 5.
  • Right to withdraw your consent at any time.

You can exercise your rights at any time and free of charge in the following ways:

  • Sending an email to privacy@glucube.com indicating the right you wish to exercise and your identifying details.
  • Sending a written request to Igluco Tech, Avenida República Argentina, 25, 8th floor, (41011) Seville, indicating the right you wish to exercise and your identifying details.

Additionally, you have the right to file a complaint with the Spanish Data Protection Agency if you believe a data protection violation has been committed regarding the processing of your personal data.

5. Detailed information on the processing activities performed by service:

IGLUCO TECH, S.L. will process your personal data when you provide it in the following ways:

  • Account registration and profile settings data: When creating an account in GLUCUBE APP, the following data will be stored: email address, password for authentication, name, surname, date of birth, country, physiology, height, weight, and target glucose ranges. The GLUCUBE APP collects information obtained from the connected GLUCUBE device and other information, such as medication records, insulin, food consumption, or physical exercise, and blood glucose readings from other sources.
  • GLUCUBE device information: When using the GLUCUBE APP with the measurement device, we will automatically receive technical information such as the MAC address of the measurement device and other data about it, the type of smartphone you are using, and its operating system.

We will also collect information about your use of the GLUCUBE APP, such as measurement errors, to ensure the app functions correctly.

  • Customer support: If you contact us regarding the GLUCUBE APP or the GLUCUBE product, or for any other customer service-related reason, we will keep a record of the contact. You may provide your personal data by filling out forms, through email, instant messaging, ordering products or services, making inquiries or requests, or reporting an issue with the GLUCUBE APP, as well as in other similar situations where you choose to provide us with information.
  • Geolocation information: If you accept and activate location permissions, which are necessary during the pairing process with the GLUCUBE measurement device, we will collect information about your exact location from your smartphone. You may withdraw your consent to stop the collection of your location information at any time; this may cause issues with pairing your GLUCUBE devices with your smartphone. These permissions are necessary for the proper functioning of the GLUCUBE measurement device, which connects via Bluetooth to the app. Under no circumstances is the user's physical location obtained; this permission is solely used for the connection with the GLUCUBE device and the measurements taken. We also use this information to improve our products and services, including identifying the distribution of GLUCUBE devices.

5.1.- Purpose of the processing

We will not use your data for any purpose not stated in this privacy policy, nor will we send additional unsolicited information without your explicit consent.

The data collected in the GLUCUBE APP, as outlined in the section “Detailed information on the processing activities performed by service,” will be used for the following purposes:

  • To provide you with cloud service when you register as a user, which will allow you to synchronize your data in a secure environment, enabling you to back up and recover your data at any time and from any compatible device.
  • To respond to and manage your requests, such as assistance requests for the GLUCUBE APP or our GLUCUBE product.
  • To continue developing, testing, and improving the GLUCUBE APP and the GLUCUBE product, including offering new features and capabilities.
  • To issue safety notices or take corrective actions related to the GLUCUBE APP or our devices when necessary.
  • To send users information or updates related to the GLUCUBE APP or the GLUCUBE product through any means, including email.

5.2.- Data retention

Additionally, we inform you that your data will remain blocked for handling legal, administrative, or tax claims for the periods required by applicable legislation.

6. Security

Igluco Tech has implemented and maintains the security levels required by the GDPR to protect the personal data of individuals from accidental loss and unauthorized access, processing, or disclosure, considering the state of technology, the nature of the data stored, and the risks they are exposed to.

However, the transmission of information over the Internet is not completely secure. Therefore, while Igluco Tech makes every effort to protect individuals' data, it cannot guarantee the security of the data during transmission to the app.

Therefore, all the information you provide will be sent at your own risk. Once we receive your data, Igluco Tech will use strict procedures and security features to prevent unauthorized access.

In the event of a personal data security breach, as long as it is not unlikely that the breach constitutes a risk to the rights and freedoms of individuals, Igluco Tech will notify the Spanish Data Protection Agency within 72 hours of becoming aware of the incident, describing the nature of the breach, the possible consequences, and the measures taken or proposed to remedy the security breach. Where possible, we will indicate the categories and approximate number of individuals and data affected.

Additionally, individuals will be notified as soon as possible when it is likely that the personal data breach will pose a high risk to the rights and freedoms of individuals, describing the possible consequences and the measures taken or proposed to remedy the security breach.

You are responsible for protecting against unauthorized access to the GLUCUBE APP and your account. IGLUCO TECH, S.L. recommends using a secure password that includes a combination of uppercase and lowercase letters, numbers, a minimum length of 8 characters, and differs from passwords used for other accounts you may have. You must keep your account password confidential and not share it with anyone.

IGLUCO TECH, S.L. will not be responsible for lost, stolen, or compromised passwords or unauthorized access to your GLUCUBE APP account when caused by you. If you believe your account is at risk, please contact us as soon as possible via email at privacy@glucube.com

7. Confidentiality

The personal data we may collect through the app or through the various communications we have with you will be treated confidentially, and we are committed to maintaining the confidentiality of such data in accordance with applicable law.

8. Privacy policy updates

It is possible that this policy may need to be updated, so it is necessary to review it periodically and, if possible, every time you access the application, to stay adequately informed about the type of information collected and its processing. You can find the privacy policy at the bottom of the app.

Notwithstanding the above, we will notify you of any changes to this policy that affect the processing of your personal data.

This privacy policy is currently in effect.

9. Data transfers and international transfers

No international data transfers are made.

IGLUCO TECH, S.L. will not share your personal data with third parties without your express consent.

Users may share their personal data with the professionals they choose through a link generated via the APP and the web platform. Once the link is made, professionals will have access to the data provided by users to GLUCUBE APP so that the professionals can monitor the users.

For users to share their data with the professionals of their choice, they must provide a code previously generated from the GLUCUBE APP, by any other communication means outside the GLUCUBE APP (email, instant messaging, etc.).

The professional must access your data through an account on the GLUCUBE web platform.

The professional may only use the linked user's data to monitor and supervise the user and provide the necessary advice during the period determined by the user.

By accepting the user's invitation, the professional expressly authorizes IGLUCO TECH, S.L. to transfer the professional's personal data, including their email address, name, and surname, to the user whose invitation has been accepted, for the purposes outlined in this paragraph.

In any case, the professional's personal data will not be transferred or shared by IGLUCO TECH, S.L. with any third party other than the user who invited them and whose invitation has been accepted, without the prior express consent of the professional.

Professionals can add or remove linked patients at any time. Users can request that IGLUCO TECH, S.L., through any of its communication channels, remove linked professionals to stop sharing their data.

We may provide your personal data when necessary to respond to legitimate requests from competent authorities or by legal obligation, including for reasons of national security. Where required by applicable law, we may also disclose your personal data when necessary to enforce or apply our end-user license agreement, this privacy policy, or other agreements, to investigate or protect the rights, property, and safety of IGLUCO TECH, S.L., our products and services, our customers, distributors, and business partners, or to prevent or take action regarding illegal activities or fraud, situations that pose a potential risk to anyone's safety, or as evidence in legal proceedings. Your personal data may be subject to foreign laws and may be accessible to public administrations, judicial bodies, and regulatory authorities from other countries.