Jade Privacy Policy

General Statement

Jade provides the website located at JadeDiabetes.com (the “Website”) and Jade Apps (the “Apps”) to support people with diabetes and healthcare providers by providing their end users with access to certain third party applications, programs, and/or devices that the end users may elect to connect to using the Website and Apps (collectively, the “Service”).

This privacy policy (“Privacy Policy”) applies to the Service and describes the information we collect, how we use it, with whom we share it, and other matters relating to such information.

The Company manages the information collected by and through the Service and may use that information for the purposes described in this Privacy Policy. The Company may also create, maintain, use and commercialise de-identified and aggregated datasets derived from information collected through the Service, subject to applicable privacy laws, contractual obligations and the safeguards described in this Privacy Policy.

Nothing in this Privacy Policy transfers ownership of an individual’s personal information or limits any rights that an individual may have under applicable privacy laws.

If you have any questions or concerns about our Privacy Policy, please contact our privacy team.

The information we collect

 In this section we provide you with details about some of the information we currently collect about users of our Service (collectively, “User Data”).

• User Key. Your Jade portal provides us with a user key (the “User Key”) that identifies you as a registered member of the healthcare portal.  This allows us to verify that we are authorized to provide you with the Service.

• Program Data.  We will collect data produced by your use of or uploaded by you to certain integrated third party applications, programs and/or devices that you may elect to use in connection with the the Service (“Programs”), e.g. Apple HealthKit. We provide you with information about Programs that connect with the Service.  These Programs typically have features that collect and store data and/or other information about you and/or permit you to upload the same to your user account with the Program. When you choose to integrate these Programs with the Service, they will be able to provide us with access to some or all of that data and/or other information (the “Program Data”. You should review information from the Programs, including their privacy statements and terms of use, prior to using them or allowing them access to any information about you.  These Programs are not sold, designed or manufactured by the Company.  All support for these Programs is provided by the Program provider.  The Company does not warrant and is not responsible for the quality, use or operation of the Programs and your use of any such Programs is governed by separate terms of use and privacy statements by the Program provider. Program Data may contain personal information and sensitive health information and is handled in accordance with this Privacy Policy, our Health Information and Data Protection Policy, and applicable privacy and data protection laws. Where Jade processes information on behalf of a healthcare organisation or other partner, additional contractual and regulatory requirements may apply. If authorized by you, we share the Program Data with your healthcare provider. Only the healthcare provider will be able to associate any Program Data with an individual user. We may de-identify and anonymise Program Data and other User Data in accordance with appropriate recognised standards and applicable privacy requirements. Subject to these requirements, we may use, disclose, license or otherwise commercialise de-identified and aggregated datasets with business partners, researchers, healthcare organisations and other commercial or non-commercial third parties for lawful research, statistical, analytical, product development and other legitimate business purposes.

• Cookie Information. “Cookies” are small files that a site or its service provider transfers (if you allow) to your computer, mobile phone or other device with a web browser and data storage capability that enables the sites or service provider’s systems to recognize your browser and capture and remember certain information. Most web browsers will accept cookies by default, but they can be set to reject cookies, either from all websites or from specific sites. You can also manually delete cookies from your web browser. These options are generally set through a “Privacy” setting in your browser setup, but you should know that in some cases blocking, rejecting or deleting cookies may impact your ability to use the Service. We use cookies to help remember you as a user. We may also use cookies in the future in other ways to provide and to improve the Service, to make the Service easier to use, or for other similar purposes.

• Navigational Information. We may collect and use non-personally identifiable information and data from you when you are using the Service through the standard operation of our Internet servers. Non-personally identifiable information collected from you may include user Internet Protocol (IP) addresses, browser type and version, domain names, referring/exit pages, operating system, date/time stamp, click stream data and anonymous statistical data regarding your use of the Service. For example, we can tell which Internet Service Provider our users use, but not the names, addresses or other information that would allow us to identify particular users. We use this information to analyze trends, to administer and to improve the Service, to track users’ movements through the Service and to gather demographic and other aggregate information (as described in more detail below) about our user base as a whole.

• Clear Gifs. We may also employ a software technology called “clear gifs” (also known as “web beacons” or “web bugs”) that helps us better manage content on the Service by providing us feedback as to what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. In contrast to cookies, which are stored on your web enabled device’s hard drive, clear gifs are embedded invisibly on a website page, web-based document or email message and are about the size of the period at the end of this sentence. Clear gifs may be used in our HTML-based emails to confirm receipt of, and response to, our emails, including those that you forward to other recipients.

• Site Information. Due to communications standards on the internet, when you visit the Service we typically automatically receive the URL of the site from which you came and the site to which you are going when you leave our Website. We also receive the internet protocol address of your computer (or the proxy server you use to access the Internet), your computer operating system and type of web browser you are using, your mobile device and mobile operating system, as well as the name of your ISP or your mobile carrier. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have enabled.

• Site Analytics. We may analyze your use of the Service with third party software that allows us to monitor and record your navigation and usage activities, in order to better customize and improve our Service and other products.

• De-Identified & Aggregated User Data: In an ongoing effort to better understand, serve and support users of the Services, we may conduct research, statistical analysis and other analytical activities using User Data collected through the Services.

  We may de-identify, anonymise, reformat, supplement, compile, analyse and aggregate User Data to create datasets and derived information that do not reasonably identify individual users (“De-identified and Aggregated Data”).

  We may use such De-identified and Aggregated Data for research, statistical analysis, the development and improvement of products, services and technologies, and other lawful commercial purposes. We may also disclose, license or otherwise make such datasets available to business partners, researchers, healthcare organisations and other third parties, subject to appropriate safeguards and applicable laws.

  We do not disclose identifiable User Data to affiliates, agents or business partners except as expressly described in this Privacy Policy or as otherwise permitted by applicable law.

  We may disclose De-identified and Aggregated Data to affiliates, business partners, researchers and other third parties for the purposes described in this Privacy Policy.

  De-identified and Aggregated Data is prepared with the intention that individual users cannot reasonably be identified from the information, taking into account the nature of the data, the means reasonably available for identification and the context in which the data is used or disclosed.

How we use the information we collect

We use the information we collect to continually try to improve our Service and to provide a safe, efficient, and customized experience. In particular, we may use your User Data to do any of the following:

• To manage and improve our service. We use the information we collect to provide our Service and other services and features and to measure and improve the Service and other services and features provided by us.  We may use User Data to provide, manage, maintain and improve our Services. We may also use appropriately de-identified and Aggregated Data to conduct research, develop and improve proprietary technologies, analytical methods, products and services, and create new commercial offerings, including through the development of intellectual property. These activities may involve statistical, computational and other automated analytical techniques.  We may also use the information we collect to enforce our Terms. We also use a variety of technological systems to detect and address anomalous activity, some of which require the use of User Data.

• To create backup files.  We create back-up copies of the Program Data we provide to your healthcare portal provider.

• To describe our services.  We may disclose, license or otherwise commercialise De-identified and Aggregated Data to current and prospective business partners, researchers, healthcare organisations, technology companies and other third parties for lawful research, statistical, analytical, product development and commercial purposes.

  Such arrangements may involve the provision of datasets, research outputs, analytical services or other derived information, subject to appropriate contractual, security and privacy safeguards.

• To comply with law.  We may use any of your User Data as necessary in order to comply with any applicable laws, regulations or court orders.

How the information we collect may be shared

• Sharing with Healthcare Providers.  If you authorize it, we share the Program Data we collect from the Programs with your healthcare provider

• Outside Contractors. We may employ independent contractors, vendors, suppliers and other third parties to support our services and products (including the Service), such as hosting, monitoring and maintaining the Service, administering or monitoring emails, analyzing our users’ preferences, developing or improving applications for the Service and providing other related services. Outside contractors may access or process User Data only to the extent necessary to provide services to Jade. Access is restricted to authorised personnel and subject to appropriate confidentiality, security, privacy and contractual obligations. Contractors are not authorised to use User Data for their own independent purposes. We also require outside contractors to protect the privacy of your User Data under privacy policies or confidentiality agreements that are at least as protective of your User Data as this Privacy Policy, and will not authorize them to use your User Data except for the express purpose for which it is provided.

• Legal Compliance. We may disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect the Company’s rights or property.

• Business Transfers. We may also disclose and/or transfer your User Data to third parties in connection with a corporate transaction, such as a merger, acquisition by another company or sale or other transfer of all or a portion of our business or assets.

Links and Advertising

We do not provide any User Data to advertisers or otherwise to third parties for the purpose of advertising or marketing.  From time to time, the Service may contain hyperlinks (“Links”) to third parties, including third party providers of certain Programs.  Such Links are for your reference only, and we neither control the privacy policies of such linked websites nor are we liable or responsible in any way for the use of any personally identifiable information that you may provide such sites.  We recommend that you remain aware when you leave the Service and review the terms of use and privacy policies of each and every linked website.

You should also be aware that if you voluntarily disclose personally identifiable information in an email or other communications with any third party listed on the Service or in other materials, that information, along with any other information disclosed in your communication, can be collected and correlated and used by such third parties and may result in your receiving unsolicited messages from other persons. Such collection, correlation, use and messages are beyond our control.

Security

• Steps we take to keep your information secure. The security of your User Data is important to us. We have put in place physical, electronic, and managerial procedures to safeguard and secure User Data from unauthorized access, including as set forth in more detail in our Data Security Policy.

• Risks inherent in sharing information. Notwithstanding our commitment to protect your information, you should be aware that there is always some risk involved in transmitting information over the internet.  In addition to the risk that the employees, contractors and others subject to our Security Policy may fail to follow required procedures, there is also some risk our or your network and/or security systems could be circumvented or breached, including by third parties who use our Service in order to do so.  As a result, while we strive to use all means to protect your User Data, we cannot ensure or warrant the security and privacy of your User Data or any other information you transmit to us, or of your or our network and/or security systems, and our and your use of the Service and your User Data is solely at your own risk.  If you have any questions regarding the security of the Service you can contact our privacy team.

Children’s Policy

The Service are for general audiences.

Enforcement

We regularly review our compliance with this Privacy Policy. Please let us know of any questions or concerns you have regarding this Privacy Policy or our compliance with this Privacy Policy by contacting our privacy team. When we receive formal written complaints, it is our policy to contact that complaining user regarding his/her concerns. We will cooperate with the appropriate regulatory authorities to resolve any complaints regarding the transfer of personal data that cannot be resolved between the Company and an individual or entity.

Your use of the Service is also governed by our Terms.