Please read this Privacy Notice (the “Privacy Notice”) carefully before accepting it and installing the FreeStyle LibreLink mobile application (the “FreeStyle LibreLink app”), which will submit your personal information, including health-related information, to Abbott Diabetes Care Inc. (referred to as “Abbott”, “us”, “our”, or “we” in this Privacy Notice). BY ACCEPTING THIS PRIVACY NOTICE AND USING THE FREESTYLE LIBRELINK APP, YOU AFFIRM THAT YOU ARE OF LEGAL AGE TO CONSENT TO THIS PRIVACY NOTICE, AND THAT YOU ARE AGREEING EITHER ON YOUR OWN BEHALF, OR ON BEHALF OF ANOTHER INDIVIDUAL FOR WHOM YOU HAVE ACTUAL AUTHORITY TO LEGALLY CONSENT TO THIS PRIVACY NOTICE.
IF YOU ARE AN INDIVIDUAL INSTALLING, USING, OR OTHERWISE ACCESSING THE FREESTYLE LIBRELINK APP ON BEHALF OF, OR FOR THE BENEFIT OF, ANY CORPORATION, PARTNERSHIP OR OTHER ENTITY WITH WHICH YOU ARE ASSOCIATED (AN “ORGANISATION”), THEN YOU ARE AGREEING TO THIS PRIVACY NOTICE ON BEHALF OF BOTH YOURSELF AND SUCH ORGANISATION, AND YOU REPRESENT AND WARRANT THAT YOU HAVE THE LEGAL AUTHORITY TO BIND SUCH ORGANISATION TO THIS PRIVACY NOTICE. References to “you”, “your” or the “user” in this Privacy Notice includes both the individual using the app and any such organisation.
This Privacy Notice is a legally binding agreement between you and Abbott that covers the collection and use of your personal information, including health information.
Abbott recognises the importance of data protection and privacy and is committed to protecting your personal information, including health-related information. Data from the FreeStyle LibreLink app, including a user’s glucose values, are uploaded to and stored in the LibreView system. Abbott Diabetes Care Inc., of 1240 Harbor Bay Parkway, Suite 290, Alameda, CA 94502, USA, is the data controller of all personal information transmitted to the LibreView system.
This Privacy Notice explains how we handle the personal information, including health-related information, that you provide to us through your use of the LibreView system (including if you use the LibreView system and FreeStyle Libre software concurrently). This Privacy Notice supplements the notices on the LibreView website. For United States Users: please note that any health information provided to us by your health care provider through the LibreView System will be additionally governed by our HIPAA Notice of Privacy Practices, available on the LibreView website located at [www.Libreview.com].
This Privacy Notice does not apply to personal information collected through the use of other websites controlled by Abbott (including its subsidiaries and affiliates), the use of FreeStyle Libre software, the use of other third-party web sites, or information collected off line.
Any terms in any purchase order or other documentation issued by or on behalf of you that contains additional or conflicting terms or purports to replace, reject, modify, or be a counter offer to this Privacy Notice are expressly rejected and are void as such.
Please note that the headings in this Privacy Notice are for your convenience only, and do not limit, define, or fully explain each section.
YOUR USE OF THE FREESTYLE LIBRELINK APP CONSTITUTES, AND IS CONDITIONED UPON, YOUR AGREEMENT TO BE BOUND BY THIS PRIVACY NOTICE AND YOUR CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION, INCLUDING HEALTH-RELATED INFORMATION. IN CERTAIN EXCEPTIONAL CIRCUMSTANCES, ABBOTT’S DATA PROCESSOR, NEWYU, MAY NEED TO ACCESS YOUR PERSONAL INFORMATION, INCLUDING HEALTH-RELATED INFORMATION, TO RESOLVE A CUSTOMER SERVICE ISSUE FOR YOU. IF YOU LIVE OUTSIDE THE UNITED STATES, AND WHERE CONSENT IS REQUIRED BY LAW, YOU CONSENT TO THE ACCESS AND TRANSFER OF SUCH INFORMATION IN SUCH CIRCUMSTANCES. BY CLICKING “ACCEPT”, YOU EXPLICITLY CONSENT AND AGREE THAT THIS PRIVACY NOTICE WILL APPLY TO YOUR USE OF THE FREESTYLE LIBRELINK APP AND TO YOUR USE OF THE LIBREVIEW SYSTEM AND TO THE PROCESSING AND TRANSFER OF YOUR PERSONAL INFORMATION, INCLUDING HEALTH-RELATED INFORMATION, AS SET OUT IN THE BELOW PRIVACY NOTICE. IF YOU, OR A PERSON ON WHOSE BEHALF YOU ARE SETTING UP A LIBREVIEW SYSTEM ACCOUNT, DO NOT AGREE TO THIS PRIVACY NOTICE, DO NOT CLICK ACCEPT TO THIS PRIVACY NOTICE AND DO NOT DOWNLOAD OR USE THE FREESTYLE LIBRELINK APP.
You can use the FreeStyle LibreLink app to collect data from your FreeStyle Libre sensor with your mobile device, which connects with the FreeStyle Libre sensor via near field communication (“NFC”). The FreeStyle LibreLink app will then use that collected data to calculate your glucose values, which will be uploaded to and stored in the LibreView system. The LibreView system is a secure, cloud-based diabetes management system that is intended for use by individuals to aid in the review, analysis, and evaluation of historical glucose data, glucose test results, and ketone test results to support an effective diabetes health management program. Use of the LibreView system may require compatible devices; internet access or data usage (charges may apply); certain software (fees may apply); and periodic updates, and the performance of the LibreView system may be affected by these requirements.
Abbott is the developer of FreeStyle Libre sensors for the FreeStyle Libre flash glucose monitoring system (“FreeStyle Libre system”) and is the data controller of your personal information, including health-related information, within the LibreView system. Abbott developed the FreeStyle LibreLink app and holds the marketing authorisations/registrations for it.
Newyu, Inc. holds the marketing authorisations/registrations for the LibreView system, and provides the system to you as a data processor of Abbott.
THE FREESTYLE LIBRELINK APP AND THE LIBREVIEW SYSTEM ARE NOT INTENDED FOR THE DIAGNOSIS OF OR SCREENING FOR DIABETES MELLITUS. USERS SHOULD BE AWARE THAT THE LIBREVIEW SYSTEM IS MERELY AN INFORMATION MANAGEMENT SERVICE AND IS NOT INTENDED TO BE A SUBSTITUTE FOR THE ADVICE OF A HEALTH CARE PROFESSIONAL. INDIVIDUALS SHOULD ALWAYS CONSULT THEIR DOCTOR OR OTHER QUALIFIED HEALTH CARE PROFESSIONAL WITH ANY QUESTIONS THEY MAY HAVE REGARDING A MEDICAL CONDITION, INCLUDING ANY QUERIES OR CONCERNS ABOUT DIABETES MANAGEMENT. YOU SHOULD NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY IN SEEKING IT BECAUSE OF INFORMATION TRANSMITTED TO OR CONTAINED IN YOUR LIBREVIEW SYSTEM ACCOUNT. You should follow customary guidelines set by your doctor or other healthcare professional(s) when your readings are too high or low or if you experience other diabetes-related changes in your medical condition. ABBOTT IS NOT A PROVIDER OF MEDICAL CARE AND ABBOTT IS NOT RESPONSIBLE FOR NOTIFYING AN INDIVIDUAL’S DOCTOR OR OTHER HEALTHCARE PROFESSIONAL(S) OF ANY CHANGES IN YOUR READINGS. The LibreView system is designed to help individuals and their healthcare professionals better manage diabetes through information, analysis, and communication. You and your doctor and other qualified healthcare professional(s) are solely responsible for communicating your glucose levels and other diabetes-related information, providing feedback, and discussing and recommending testing and treatment options. Abbott does not recommend or endorse any specific tests, products, procedures, or opinions. YOUR DECISION TO TAKE ACTION BASED ON ANY INFORMATION TRANSMITTED TO OR STORED ON THE LIBREVIEW SYSTEM OR ON ANY INFORMATION RECEIVED FROM ABBOTT EMPLOYEES, AGENTS, OR SUPPLIERS IS SOLELY AT YOUR OWN RISK.
Please be aware that third parties may offer unauthorised services, software, and mobile apps that may claim to be compatible with Your FreeStyle Libre sensor, the FreeStyle LibreLink app, and/or the LibreView system but are not authorised by Abbott for such use. Abbott does not recommend using the FreeStyle Libre sensor or the FreeStyle LibreLink app with these unauthorised third party products, and is not responsible if you do. If you do use these third party products or services, your use would be subject to their respective privacy policies and terms of use.
This Privacy Notice applies only to the personal information you submit when creating an account in the LibreView system and to the personal information, including health-related information, that we may receive from you or your healthcare provider or others as set forth herein and stored within the LibreView system. Data will be uploaded to the LibreView system when you use the FreeStyle LibreLink app to scan your Abbott FreeStyle Libre sensor and through any customer services we provide that are connected to your use of the LibreView system. You may also be able to access your account for the LibreView service via a website domain, depending on your country of residence; however, use of any LibreView website will be subject to an additional privacy notice on that website. This Privacy Notice does not apply to any other personal information provided by you or collected from you by Abbott.
This Privacy Notice covers the following information:
In some countries, we may provide other functionality and features to the FreeStyle LibreLink app, and you may be able to upload additional personal information to your account in the LibreView system, such as:
The FreeStyle LibreLink app transmits data directly to the LibreView system, which will then handle your personal information pursuant to this Privacy Notice. You may manage how your FreeStyle LibreLink app interacts with your LibreView system account by accessing the FreeStyle LibreLink app settings. You may also use the FreeStyle LibreLink app to change your settings on the LibreView system.
Abbott will use your personal information, including health-related information, in the following ways:
If in addition to using the LibreView system, you also use FreeStyle Libre software, the LibreView system and the FreeStyle Libre software will collect information separately. Abbott will never combine these two data flows (the de-identified data obtained through the FreeStyle Libre software and the data uploaded to the LibreView system) for the purposes of re-identification. Abbott uses technical and organisational measures to ensure that these data flows remain separate. This supplements the FreeStyle Libre Software Privacy Policy accordingly.
YOU AGREE THAT BY CREATING A LIBREVIEW SYSTEM ACCOUNT AND BY ACCEPTING THIS PRIVACY NOTICE, YOU CONSENT TO THE PROCESSING OF YOUR SENSITIVE HEALTH-RELATED INFORMATION AS SET OUT HEREIN.
For United States Users: When you provide your healthcare providers access to your LibreView System account, that action constitutes your direction to the healthcare providers to disclose to you and Abbott (through the LibreView System), your personal information, including health-related information, they believe to be relevant for the purposes set forth in this Privacy Notice. You are further directing your healthcare providers to continue to disclose your personal information and health information as directed above, until you cancel this direction by contacting the healthcare providers and/or Abbott as stated in this Privacy Notice. You understand that if you cancel this direction, the cancellation will not apply to any information already used or disclosed to Abbott prior to Abbott’s and your healthcare providers’ receipt of the cancellation.
We use information obtained from your mobile device in providing you with a LibreView system account. We also use information obtained from your FreeStyle Libre sensor and your mobile device to help us fix any issues with the FreeStyle LibreLink app or the LibreView system, and as otherwise described in this Privacy Notice. Some of this information collected for the purposes of resolving any issue(s) with the LibreLink app may include your personal information or may be capable of being connected to your personal information. To the extent such personal information is received, we will comply at all times with applicable laws.
We use de-identified, pseudonymised, aggregated, and/or anonymised information, which is information with which Abbott cannot identify you individually, for the following reasons:
We share personal information with our third party suppliers solely to provide, maintain, host, and support the LibreView system. Newyu, which holds the marketing authorisations/registrations for the LibreView system, will process personal information, including health-related information, on our behalf as a third party supplier. Where we provide your personal information to third party suppliers to assist us with the provision of your LibreView system account, they are required to keep your personal information confidential and secure and to use your personal information to the minimum extent necessary. If you select France as your country of residence: the hosting of your LibreView system account in the cloud will be hosted in France by Orange Business Services, accredited by the ASIP Santé to host health-related information. If you select a country in Europe other than France as your country of residence: the hosting of your LibreView system account in the cloud is by Amazon Web Services in Europe.
Abbott uses the service provider Firebase, an affiliate of Google Inc., to report when the FreeStyle LibreLink app crashes or experiences certain scanning errors so that we can support and improve the FreeStyle LibreLink app. If the FreeStyle LibreLink app crashes or experiences certain scanning errors during normal use, the FreeStyle LibreLink app will send certain information about the incident to Firebase. The information sent to Firebase will not involve the use of your personal information.
We may share your personal information with third parties (including affiliated Abbott companies) with whom we are jointly marketing a product or service or jointly conducting a program or activity, for example, where you opt in to receive further information from your local Abbott affiliate. We also may share your personal information with third parties where you have expressly asked us to do so. We will not sell or license your personal information to third parties except in connection with the sale, merger, or transfer of a product line or division, so that the buyer can continue to provide you with information and services. For the avoidance of doubt, we will never sell your personal information for commercial purposes to third parties and we may only share your personal information with third parties where you have provided consent or where permitted by applicable law.
We reserve the right to disclose your personal information to respond to authorised information requests from government authorities, to address national security situations, or when otherwise required by law. Furthermore, where permitted or required by law, we may also disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Privacy Notice, or as evidence in litigation in which we are involved. Your personal information may be subject to foreign laws and may be accessible by foreign governments, courts, law enforcement, and regulatory agencies.
We have implemented administrative, technical, and physical safeguards to protect your personal information, including health-related information, from unauthorised or unlawful access, accidental loss, destruction, damage, misuse, disclosure, and alteration, including through the use of cryptographic technologies. Abbott restricts access to personal information by its employees on a need to know basis. Please keep in mind that no internet or WiFi transmission is 100% secure, so please exercise caution when uploading personal information, especially health-related information, to your LibreView system account.
You are responsible for protecting against unauthorised access to your LibreView system account. We recommend securing access to your mobile device by logging-out, choosing a robust password that nobody else knows or can easily guess, and keeping your account information and password private. Abbott is not responsible for any lost, stolen, or compromised passwords or for any activity on your LibreView system account from unauthorised users where caused by you. If you think your account has been compromised, please contact us as soon as you are able at DiabetesCarePrivacy@Abbott.com.
The personal information transmitted to the LibreView system will be stored in the cloud on secure servers.
When your personal information is hosted in a country other than the country you selected, it may become subject to the laws of the host country, which may not be equivalent to the laws of the country you selected. However, Abbott will put appropriate measures in place to protect your personal information and ensure that your personal information is only be collected, used, and disclosed as permitted under applicable laws.
If you select a country outside the United States as your country of residence:
Abbott (or its affiliates) may send you advertising and marketing-related information about diabetes care or their other products and services if (where required by law) you opted-in to receive such communications when you set up your LibreView system account profile. You may receive marketing information which is tailored to your specific needs based on the information uploaded or connected to your LibreView system account (including health-related information). We may also invite you to participate in surveys about our products, provide you with news and newsletters, or to notify you about special offers and promotions. These materials may be sent by us or by one of the companies in the Abbott Group. You may opt out from receiving marketing-related communications by either clicking on the unsubscribe link at the bottom of marketing-related emails we send you, by changing your LibreView preferences, or by contacting us at DiabetesCarePrivacy@Abbott.com. We will process opt-out requests without undue delay.
Neither Abbott nor its affiliates or licensors will send advertising or marketing-related information to children.
Each user is required to enter his or her date of birth and country so that we may establish whether the user is a child under the law of the user’s country. If a date of birth attributable to a child is entered, the user will be required to enter the email address of a parent/guardian before a LibreView system account will be created. The parent/guardian must consent to the child’s use of the LibreView system. Upon such consent, a LibreView system account will be created for the parent/guardian for use by a child.
Where a child wishes to use any functions in the FreeStyle LibreView system which act to disclose their personal information, including health-related information, to any other party, the child is prevented from doing so without obtaining the consent of his or her parent/guardian. Before a child may take such an action, the parent/guardian is required to enter his or her password to enable this functionality. We will send parents/guardians notice via their registered email address when such settings have been accessed, and it is the parent’s/guardian’s responsibility to manage these settings for the child.
At any time, a parent/guardian may stop the collection of a child’s personal information, including health-related information, by requesting that Abbott delete the LibreView system account used by a child by contacting us at DiabetesCarePrivacy@Abbott.com. This action will delete the account being used by the child but we retain aggregated and de-identified information and may need to retain certain personal information as required by law.
You may correct your profile information through the LibreView system account settings within the FreeStyle LibreLink app. We are not able to correct/amend FreeStyle Libre sensor readings stored in the LibreView system account, but will assist you with deleting your FreeStyle Libre sensor readings so that that you can reload the correct information.
You may have the right to access the personal information we hold about you and/or to request we correct, delete, or take other action in connection with your personal information, subject to applicable law. To request the exercise of these rights, please contact us at DiabetesCarePrivacy@Abbott.com.
Children may also have the right to access the personal information held about them through the LibreView system, but we may receive a request for access from a child’s parent/guardian and, in some circumstances, we may respond directly to the child’s parent/guardian.
If you would like to delete your LibreView system account, please contact us at DiabetesCarePrivacy@Abbott.com. Please be aware that if you delete your account, we will retain aggregated and de-identified information and may need to retain certain personal information as required by law.
Once your LibreView system account and any associated personal information has been deleted, you will no longer have access to the LibreView system and deletion of your account may be irreversible. You may not therefore be able to reactivate your LibreView system account or retrieve any personal information, including health related information, so you may want to download and save any required information before requesting that we delete your account from the LibreView system.
If you have chosen to share your LibreView system account information with your healthcare professional, family members, and/or friends and you delete your account, those persons will no longer be able to view your glucose readings.
Abbott reserves the right to delete inactive LibreView system accounts after 6 months. We will notify you in advance so that you have an opportunity to ensure your account stays current and available for your use.
If you have questions, comments, or complaints about our privacy practices, please contact us by clicking on the “Contact Us” link on one of our web sites, or emailing us at DiabetesCarePrivacy@Abbott.com. Alternatively, you may send a letter to the following address:
Attn: Legal Department
Abbott Diabetes Care Inc.
1420 Harbor Bay Parkway, Suite 290
Alameda, CA 94502
USA
In all communications to us, please include the email address used to create your LibreView system account and a detailed explanation of your request.
If you would like us to amend or delete the personal information we hold about you and are contacting us by email, please put “Amendment Request” or “Deletion Request”, or other right as applicable, in the subject line of the email. If you would like to access the personal information we hold about you, please put “Access Request” in the subject line of the email. We will do our best to respond to all reasonable requests in a timely manner, or at the very least, in accordance with any applicable legal requirement.
For French Users:
It is important that you select France as your country of residence when installing the FreeStyle LibreLink app. If you have incorrectly identified a different country as your country of residence, do not complete the installation. Instead, re-start the download of the FreeStyle LibreLink app and select France as your country of residence.
Pursuant to the Law n°78-17 of the 6 January 1978 on Information technology, data files and civil liberties, the Data Controller for your LibreView System account is Abbott Diabetes Care, Inc., 1420 Harbor Bay Parkway, Suite 290, Alameda, California 94502 United States.
Abbott Diabetes Care processes your personal data for the purpose of providing your LibreView System account as more fully set out in “How does Abbott use personal information?”, except that Abbott will not send you any tailored marketing information. Abbott will also process information obtained from your mobile device in providing you with a LibreView system account and to help us fix any issues with the LibreView system. We will not use your data for the other purposes, in particular, analytics as further described in the section entitled “How does Abbott use other types of information?” The section entitled “Will Abbott send me marketing material?” does not apply to users in France. You consent to the processing of your personal data and sensitive personal data as set out herein.
The recipients of the data are its data processors involved in storing and hosting of your account, in particular, Orange Business Services, an accredited health data host located in France. Orange may provide customer support related to the hosting of your data. In exceptional circumstances where Orange is unable to resolve the customer support issue, Newyu based in the United States, may need to access the servers and/or access your data to resolve the customer support issue related to your account, and you consent to a transfer of your data to Newyu for the purpose of receiving such support. We will not share your data with any other third parties, including any other affiliated Abbott companies nor will we transfer your data for any other reason.
You have a right of access and rectification concerning information related to you. You can access information about you by contacting us at DiabetesCarePrivacy@Abbott.com, at Abbott Diabetes Care at the above address or by writing to Abbott Diabetes Care France (Diabétologie), Bâtiment Cologne, 12 Rue de la Couture, BP 20235, 94518 Rungis Cedex. You can also, for legitimate reasons, oppose the processing of your personal data.
If we change our privacy practices, an updated version of this Privacy Notice will reflect those changes. You will be alerted to updates simultaneously with your being asked to install an update to your FreeStyle LibreLink app. This means that when you install an updated version of the FreeStyle LibreLink app on your mobile device, you will also be notified if there is a new version of this Privacy Notice and will be prompted to read and accept it so that you can continue to access and use your LibreView system account via the FreeStyle LibreLink app. Without prejudice to your rights under applicable law, we reserve the right to update and amend this Privacy Notice without prior notice to reflect technological advancements, legal and regulatory changes and good business practices to the extent that it does not change the privacy practices as set out in this Privacy Notice.
If you do not agree to the changes to the Privacy Notice, you should request deletion of your LibreView system account by contacting us at DiabetesCarePrivacy@Abbott.com.
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