Privacy Policy

Ypsomed takes the issue of Personal Data protection very seriously. We organise our data processing in line with the objective of collecting, processing or using only the personal data that is required for the reasonable and economic use of our services.

In what follows, you will find out when data is collected during your use of the Ypsomed  mobile application and web-based apps, including the Ypsomed app (collectively "Ypsomed Software") and how we use this data. We have taken organisational measures to ensure compliance with laws and regulations protecting the privacy of individuals and applicable in Canada ("Privacy Laws").

By clicking on the appropriate box after reading this Privacy Policy, you agree to the collection, use, processing and disclosure of your Personal Data (as defined below) in accordance with this Privacy Policy which shall be deemed part of the terms of use for any service or software provided by Ypsomed.

If you do not agree with any aspect of this Privacy Policy, you may not use the services or software provided by Ypsomed.

Scope of application

In these Data Protection Regulations, the words "we", "our", "us" refer to:

•Ypsomed Canada Inc., 605-1 av. Holiday, Pointe-Claire, QC H9R 5N3 Canada

(hereinafter "Ypsomed")

Personal Data

Ypsomed collects, processes and uses your Personal Data in compliance with this Privacy Policy and Privacy Laws. The term "Personal Data" refers to information about an indentifiable individual.

Our online offer can be used to a certain extent without the disclosure of your identity. In the event of your participation in one of our personalised services, you will be asked separately for the data required for us to provide the services. You can freely choose whether you wish to participate in these services and provide Personal Data accordingly.

Type and extent of data collected and their use

a) When registering in order to download Ypsomed Software, you must provide Personal Data. A more detailed description of the Personal Data we collect in this way can be found below.

Surname, first name, gender, country of origin, e-mail address, date of birth, optionally also: telephone number, fax number

These data are collected and used only for the purpose of carrying out the resulting contractual relationship and to the extent required to execute the contract between you and Ypsomed. The data can also be used to process your inquiries.

When you access our website, data that may allow identification (e.g. IP address, date, time, and pages viewed) are collected. Data allowing the identification of individuals is stored for backup purposes only and is not used unless required to assess Ypsomed's rights. These data are not use otherwise than in aggregated form which does not allow the identification of individual users.

b) Ypsomed Software allows you to provide health information. If you choose to provide Personal Data related to your health, a more detailed description of the health related Personal Data collected in this way can be found below:

Device data: blood glucose levels, insulin levels, alarms and indications of connected devices, device status information

Therapy data: blood sugar levels, insulin doses, carbohydrate intake, physical activity, physiological condition, weight, height

Health related Personal Data is used by Ypsomed solely to provide services through the Ypsomed Software and for no other purpose.

c) In order to evaluate and continuously improve the quality of our Internet offer, we undertake statistical evaluations of the visits to our pages. This is done in part by using counting graphics in our website. However, the data acquired in this way are strictly anonymised and do not allow any conclusions to be drawn regarding the Personal Data of the user or the identity of the user. Your data will never be used to create user profiles of any kind.

The aggregated data collected will be used for the following purposes:

- The provision, maintenance, improvement and development of relevant functions, content and services;

- The detection of and defence against fraudulent, abusive and prohibited activities as well as the protection and security of our services.

Log files

With every page you view, access data is stored in a log file. The data set saved contains the following data:

• Your IP address,

• the remote host (the name and IP address of the computer requesting the page),

• the time, status, volume of data transferred and the website from which you came to the requested page (referrer), as well as

• the product and version information of the browser used (user agent).

Ypsomed uses the standardised log file format of the web server for this purpose. Ypsomed uses the log data (logs) in an anonymised form, i.e. without assignment or references to your person, for statistical analysis. Ypsomed may thus, for example, find out on which days and at which times the offers of Ypsomed online version are particularly popular and what data volume is generated on the Ypsomed websites. Moreover, Ypsomed may recognise possible errors thanks to the log files, e.g. faulty links or bugs, and thus use the log files to further develop the Ypsomed online version websites. Ypsomed does not associate the page views and uses stored in the server log with individuals. Ypsomed reserves the right, however, to subsequently check the log files via the last known IP address of such users who, on the basis of certain facts, are suspected of using the Ypsomed online version of websites and/or the Ypsomed services illegally or contrary to applicable terms and conditions. This serves the protection of Ypsomed members, the security of Ypsomed member data, as well as the Ypsomed websites and Ypsomed services.

You can prevent the installation of cookies by setting your browser appropriately. When a corresponding browser setting is used, cookies will not be saved. This may mean, however, that not all features of the Ypsomed Software online version can be used.

Use of cookies

After you have logged in (with your user name and password), the services of Ypsomed Software online version use  cookies, with which you can be identified during the duration of your visit. A cookie is stored on your computer. After the end of the session, the cookie expires automatically. You can save this cookie permanently so that you can log in automatically by using the "Automatically log in to this computer" feature. The cookie will then contain parts of your log-in details in encrypted form. However, the automatic log-in to two (2) different computers is not possible in this case.

Invitations to the Ypsomed Software online version

You can use the Ypsomed Software to invite other people to join and view your online data. When you provide data about another individual to invite them to join, this data will be used exclusively for the invitation and not for other purposes. If you invite other people to view your online data we will disclose your Personal Data accordingly. We are not responsible for any action undertaken by such other people with your Personal Data.

Confidentiality

Personal Data collected by Ypsomed is confidential. Access to Personal Data is strictly limited to employees and officers of Ypsomed, on a need-to-know basis. We may also provide Personal Data to subcontractors helping us provide our services. Employees and subcontractor accessing Personal Data are informed of the confidential nature of Personal Data, are aware of this Privacy Policy and are bound by obligations of confidentiality.

Protection and storage of Personal Data

If you choose to upload your Personal Data to the cloud, Ypsomed uses Microsoft's cloud services (Microsoft Azure) with regard to the therapy and device data, including health related Personal Data, collected through the Ypsomed Software. These data are stored on servers located in Canada.

We retain your data only for as long as is required for the purposes set forth in this Privacy Policy or for the period of time in which your account is active with Ypsomed and it is necessary to do so in order to provide you with services. If you no longer wish that Ypsomed uses your data to provide the services to you, you can close your account and Ypsomed will delete the stored data insofar as Ypsomed is not obliged to keep your data for compliance with legal obligations, for settling disputes or as otherwise required by applicable law.

If we have not had any relevant contact with you for two years, we will erase your Personal Data from our systems unless we believe in good faith that we are required by law or otherwise to keep them (e.g. an enquiry in connection with a probable lawsuit).

Personal Data is stored on physical equipment operate by our service provider, on which we rely in part to ensure the security of Personal Data. Ypsomed and Microsoft have secured their servers against unauthorised access using proven and customary systems.

We expressly point out that the protection of data transfers in open networks, such as the Internet, cannot be fully guaranteed. No security measure can absolutely protect data stored on remote servers from unathorized access.

Security Breach

In the event of an unauthorized access to Personal Data, we will notify the competent authorities and affected individuals as required by Privacy Laws.

Transfer of Personal Data to other third parties

Other than as specifically authorized by you, we do not share personal information with third parties other than Microsoft (if you choose to upload your Personal Data to the cloud), for storage purposes. In particular, there is no disclosure of Personal Data to third parties for advertising purposes.

Only anonymised data can be passed on to other third parties for evaluation purposes. Anonymization is a process in which personal data is modified in such a way that the details of personal or factual circumstances can no longer – or only with a disproportionate amount of time, costs and labour – be assigned to a particular or identifiable natural person.

If, however, you use further personalised services of our offer, the collection of personalised data and their transfer to third parties may be required for the purpose of carrying out and processing the service. However, these data are only stored or transmitted to the extent required for order processing. In order to do so, when you fill in the respective form, the submission of an explicit declaration of consent is required.

Insofar as we are or will be required to do so by law or by court order, we will forward data, to the extent authorised by law, to the respective authorities entitled to receive information.

Ypsomed Software online version – Information regarding the exchange of data with other persons

Users can use the online version of Ypsomed Software to exchange data with persons authorised to receive it (e.g. doctor, person of trust authorized by the user). Please note that the linking of Personal Data with the health data must be technically possible in order to allow your doctor to assign the data to the patient.

However, Ypsomed will not associate Personal Data with health data in such a way that people other than the authorised physician can assign health data to certain persons. In no case will personal or health data be passed on to other third parties other than your authorised doctor or other third parties authorised by you to retrieve the data. Access to data contained in Ypsomed Software online version is only possible after the user ID and password have been entered. Doctors and persons of trust shall only gain access to the data after you have authorised such person to gain access, such person has logged in and such person has confirmed his/her registration when logging on. Doctors and persons of trust may use the Ypsomed Software to exchange data with patients who have authorised them to access the patient data. You can revoke the authorisation of the doctor or person of trust at any time through the Ypsomed Software or by contacting us. After revocation, access to Personal Data will no longer be possible. When you authorize a third-party (such as you doctor or person of trust) to access Personal Data, we are not responsible for any action undertaken by such third-party with respect to your Personal Data, either before or after you revoke such authorization. Ypsomed shall only be responsible to stop disclosing Personal Data with a third-party after you revoke your authorization.

Right of revocation, right to disclosure, deletion and data portability

You have the right to revoke your consent to the collection, processing and use of your Personal Data at any time, without stating reasons and with effect for the future. You can exercise this right by simply calling Ypsomed or sending the revocation to us, e.g. in writing or by e-mail at info@ypsomed.ca.

You are entitled, at any time, to access the Personal Data stored concerning you.

You can also request, at any time, the correction or erroneous Personal Data by Ypsomed .

To exercise your rights with respect to your Personal Data, contact us by email at info@ypsomed.ca. We will respond to request for access or correction of Personal Data within a reasonable delay, in most case within a maximum of 30 days.

Individuals under 18 years of age

Participation in Ypsomed services is reserved exclusively for adults or minors authorized by their parents or legal guardians. Parents or guardians are responsible for protecting the privacy of their children.

Persons under the age of 18 should not submit any Personal Data to us without the consent of their parents or guardians. We do not knowingly collect, store or disclose to any third party personal information collected from minors unless authorized by their parent or legal guardian.

Complaints and Questions

If you have complaints or question regarding your Personal Data, you may contact us as set forth below:

Email: privacy@ypsomed.ca

Telephone: 514 695 - 5959

Ypsomed Canada Inc.
1 Holiday Avenue, Suite 605
Pointe Claire, QC H9R 5N3
Canada

Modifications to the Policy

This Privacy Policy may evolve over time to reflect changes in our data processing practises. We will notify you of any change to our Privacy Policy before the coming into force of the modified Policy Policy. If you do not agree with the modified Privacy Policy, you will be afforded an opportunity to stop providing your Personal Data to Ypsomed.

 Last update: January, 2021