Privacy Policy
Welcome to the Lumipod Closed-Loop application!
The Lumipod Closed-Loop application (hereinafter referred to as the "Application" or "Software") is used to control hybrid closed-loop insulin array systems and insulin pumps (non-closed-loop pumps). During your use of our mobile application, we may collect and use your personal information. Personal information refers to various information recorded in digital or other forms that can identify a natural person's identity either alone or in combination with other information.
We will explain to you through this document the purposes, methods, and scope of the software's collection and use of your personal information, your rights regarding personal information, and the protective measures we have taken to ensure information security.
Before using the software, please read this policy carefully to understand our measures for protecting user personal information. If you do not agree with this policy, we will be unable to provide you with relevant services. If you enable the software, it indicates that you fully and clearly understand the following information collection practices and your rights.
This policy will help you understand the following:
1. What information we collect and how we use your personal information
We collect personal information to operate more efficiently and provide you with the best user experience. The channels through which we collect personal information include: (1) Information you provide directly to us; (2) Relevant information collected by us during your use of the software;
The information we collect depends on the products you actually use, the context of your interaction with us, your choices, including your privacy settings, and the products and features you use. When we collect personal information, providing such information is optional. For core functions, if you choose not to provide information, we may be unable to provide you with services and respond to or resolve your issues. For non-core functions, if you refuse to provide personal information, related features may be unavailable, but this will not affect your use of our core functions.
Account Information Related Functions: (1) You need to register and log in to an account to use the software. During registration, you need to read and agree to the Terms of Service and Privacy Policy. Your mobile phone number, email address, password, and verification code will be collected to register an account for you and log in to use relevant services. (2) When using the software, providing other basic information such as your personal nickname, real name, and gender is optional. We collect the above information to provide better software services tailored to individual conditions. When you first pair or manage paired devices (insulin pumps, CGMs) on the mobile application, we need to collect your device serial number information. We collect device serial numbers to complete the pairing of devices with the software and bind account and device information, etc. (3) If you pair a device with the mobile application, the application will synchronize data to the cloud server. We will obtain insulin pump infusion data and CGM monitoring data that you transmit to the cloud server. (5) At the same time, to fulfill cybersecurity protection obligations, ensure software functionality and your account security, and improve and optimize your service experience, we will collect your terminal device information during your use of the software, including terminal name, terminal model, IMEI number, phone model, Mac address, transmitter serial number, IP address, operating system version, and local logs. We collect the above information to verify the identity of your device and account. (6) We will strictly use your personal information for the purposes described in this policy. Your personal information will only be used for the purposes identified, described, and authorized by you at the time of collection. If we wish to use the information for other purposes not specified in this policy, we will seek your consent in advance. Without your prior consent, we will not provide users' personal information to third parties for use.
Allowing Terminal Device Permissions:
|
Permission |
Corresponding
Function/Service |
Purpose |
Ask User
for Permission? |
Optional? |
Impact of
Denying/Closing Permission |
|
Location |
To enable Bluetooth on Android phones, you need to allow the terminal device's location permission |
Enable Bluetooth function |
Yes |
Yes |
May cause Bluetooth function to fail to open; however, you can still manually open it. |
|
Bluetooth |
Used to pair insulin pumps and CGMs and receive data |
Receive insulin pump infusion data and CGM monitoring data |
Yes |
Yes |
May cause insulin pump and CGM data to be unable to transmit via Bluetooth communication |
|
Network |
Used to synchronize insulin pump and CGM data to the cloud server |
Synchronize insulin pump and CGM data |
Yes |
Yes |
May cause insulin pump and CGM data to be unable to synchronize based on account information |
|
Notification |
Used to issue reminders and alarms when insulin pump or CGM devices are abnormal |
Notify users when prompts or alarms occur |
Yes |
Yes |
May fail to receive abnormal information from insulin pump or CGM devices |
|
Do Not Disturb |
Used to issue reminders and alarms when insulin pump or CGM devices are abnormal |
Notify users when prompts or alarms occur |
Yes |
Yes |
May fail to see abnormal information from insulin pump or CGM devices in a timely manner |
(2) After allowing permissions, you can enter the system [Settings] at any time to close the corresponding permissions. After closing permissions, the corresponding functions may not work properly.
We promise not to enable device permissions in scenarios where you have not authorized them, nor to use personal information collected via enabled device permissions for scenarios you have not authorized. Exceptions apply to situations authorized by you:
You fully understand that, according to applicable laws, we do not need to seek your authorization in advance to share, transfer, and disclose your personal information in the following circumstances: (1) Related to our fulfillment of obligations prescribed by laws and regulations; (2) Directly related to national security and national defense security; (3) Directly related to public safety, public health, and significant public interests; (4) Directly related to criminal investigation, prosecution, trial, and execution of judgments; (5) When used to protect your or others' life, property, and other major legitimate rights and interests, but it is difficult to obtain your authorization; (6) The personal information involved has been publicly disclosed by you; (7) Necessary for signing and fulfilling the contract between you and us; (8) Your personal information is collected from legitimate public sources, such as legitimate news reports, government information disclosure, etc.; (9) Necessary for maintaining healthy, safe, and stable operations, such as discovering and handling product or service failures; (10) Necessary for news units to conduct legitimate news reporting; (11) For academic research institutions, it is necessary to conduct statistics or academic research in the public interest, and when providing academic research results or descriptions to the public, the personal information contained in the research results has been de-identified.
2. How we store your personal information
If we stop operating the product for specific reasons, we will notify you in a timely manner and stop collecting and processing personal information. The retention period for the collected personal information we store is five years after the product is withdrawn from the market. At the same time, you always have the right to actively request the deletion of all data through the "Delete Account" function or by sending a request email to our technical support team. At the end of any retention period or when conditions for information deletion are met, we will completely delete all collected personal information.
3. How we disclose your personal information
We only publicly disclose your personal information under the following circumstances:
You fully understand that, according to applicable laws, we do not need your authorization to collect and use your personal information in the following circumstances: (1) Related to our fulfillment of obligations prescribed by laws and regulations; (2) Directly related to national security and national defense security; (3) Directly related to public safety, public health, and significant public interests; (4) Directly related to criminal investigation, prosecution, trial, and execution of judgments; (5) When used to protect your or others' life, property, and other major legitimate rights and interests, but it is difficult to obtain your authorization; (6) The personal information involved has been publicly disclosed by you; (7) Your personal information is collected from legitimate public sources, such as legitimate news reports, government information disclosure, etc.
4. How we protect your personal information
We adopt reasonable and feasible technical security and organizational measures to protect the collected information related to our services. We have adopted industry-standard security measures to protect the personal information you provide from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonable and feasible measures to protect your personal information, including:
(1) We use mainstream security technologies such as SSL to encrypt many services. We regularly review information collection, storage, and processing measures (including physical security measures) to prevent unauthorized access or tampering with various systems.
(2) We strictly control access to personal information, allowing only employees who need to know the information to help us process personal information and personnel of service companies authorized to process personal information to access personal information. They are required to fulfill strict contractual confidentiality obligations, and failure to comply may result in legal liability or termination of their relationship with us. Access logs for personal data will be recorded and audited regularly.
(3) Your information security is very important to us. Therefore, we will continue to strive to ensure the security of your personal information and implement comprehensive security encryption measures for storage and transmission processes to prevent unauthorized access, use, or disclosure of your information. At the same time, the content of certain encrypted data cannot be accessed by anyone other than the user themselves.
(4) When transmitting and storing your special types of personal information, we will adopt security measures such as encryption; when storing personal biometric information, we will adopt technical measures to process it before storage.
(5) We will strictly screen business partners and service providers and incorporate personal information protection requirements into commercial contracts between both parties or activities such as audits and assessments
(6) We will hold security and privacy protection training courses, tests, and promotional activities to enhance employees' awareness of the importance of protecting personal information.
(7) The internet environment is not 100% secure. We will do our utmost to ensure the security of any information you send to us. Even if we make great efforts and take all reasonable and necessary measures, it is still possible that your user information may be illegally accessed, stolen, tampered with, or destroyed, causing damage to your legitimate rights and interests. Please understand the risks of the above information network and voluntarily assume them.
(8) In the unfortunate event of a user information security breach, we will notify you in a timely manner in accordance with laws and regulations: the basic situation and possible impact of the security incident, the processing measures we have taken or will take, suggestions for you to prevent and reduce risks, and remedial measures for you, etc. We will notify you of relevant information about the incident in a timely manner via email, letter, telephone, push notifications, etc. When it is difficult to notify user information subjects one by one, we will issue an announcement in a reasonable and effective manner. At the same time, we will also actively report the handling of user information security incidents to regulatory agencies as required.
5. Your rights regarding personal information
We respect your rights regarding personal information. Below is how we will protect your rights.
1. Right to Know By publishing this Personal Information Protection Policy and in accordance with laws and regulations, we will inform you of how we handle your personal information through specific announcements, SMS, or email. We are committed to ensuring transparency in the use of your information. You can regularly view this policy, receive emails and SMS about policy updates, contact us through the methods shown in this policy, and use other ways to understand the collection and use of your personal information.
2. Right of Access You can directly search or access your personal information on our product or service interface, including logging into your account at any time through the product page to access personal information related to your account. If you cannot search or access your personal information yourself, or encounter any problems when exercising your data access rights, you can contact us through the methods shown in this policy and request access to your personal information.
3. Right to Correction When you find that the personal information we process about you is inaccurate or incomplete, you have the right to request us to correct or supplement your personal information. For some of your personal information, you can correct your profile information via "Settings - General Settings - User". For personal information for which we have not yet provided a self-service correction channel, your decision to contact us through the methods shown in this policy and request correction or supplementation of your personal information will not affect your previously initiated right to complain based on authorization.
4. Right to Deletion If you use the "Delete Account" function in the software (on the "Settings" page, click Delete Account), you can completely delete your personal information in real-time. For some of your personal information, you can delete it directly on the product or service related function pages. Specifically: For personal information for which we have not yet provided a self-service deletion channel, or for personal information we collected and used in violation of our agreement with you, you can contact us through the methods shown in this policy and request us to delete your personal information.
5. Response to Your Above Requests You have the right to contact us through the methods shown in this policy and file a complaint. We will respond within 30 working days after receiving your complaint. Please note that for security reasons, we may verify your identity before processing your request. For your reasonable requests, we generally do not charge any fees. However, for repeated requests that exceed a reasonable scope, we will charge a certain fee depending on the situation. For unreasonable repeated requests, requests requiring excessive technical means (e.g., needing to develop new systems or fundamentally change existing practices), requests posing risks to the legitimate rights and interests of others, or impractical requests, we may refuse your request and inform you of the specific reasons. In addition, if your request involves matters directly related to public interest, such as national security, national defense security, public health, criminal investigation, etc., or may cause serious damage to your own or the legitimate rights and interests of other individuals or organizations, we may be unable to respond to your request.
6. Changes to the Privacy Policy
We reserve the right to update or modify this Privacy Policy from time to time. We will send you notifications of changes to our policy through various channels. For significant changes to the policy, we will send you push notifications via the software. This policy may be adjusted, but we will not weaken your rights under this policy without your explicit consent. If you do not agree to the above Personal Information Protection Policy, we will be unable to collect and use the information necessary to provide services, and thus we will be unable to provide services to you normally. This policy will take effect from the update date (December 31, 2024).
7. Contact Information
If you have any questions or concerns about our Personal Information Protection Policy or practices, please contact us: The Limited Liability Company LLC "Agata", registered in accordance with the legislation of the Russian Federation, OGRN 1182536007940, address: 690091, Russia, Primorsky Krai, Vladivostok City, Utkinskaya Street, 13 - 13
If you have any questions or concerns about our Privacy Policy or personal data processing, need to delete your data, or have privacy-related complaints, you can contact us to exercise your rights regarding data privacy.
Version: V1.0.0 Update Time: December 31, 2024