Privacy Policy

Version dated January 13, 2022

1. INTRODUCTION

1.1. Responsible entity

AIAPS France SAS, located in Paris, 203 Avenue Achille Peretti 92200 Neuilly-sur-Seine, France incorporated and registered in France with company number 903441103 (“AIAPS France”), is the stated responsible entity under the data protection regulations. AIAPS France decides on the purpose and means of processing the personal data of our users (“User Data”) and is therefore responsible for its security and compliance with the applicable laws.

1.1.2 As the responsible entity we are subject, for example, to information requirements that we wish to fulfil in connection with this privacy notice.

1.2. Structure and consent concept

1.2.1 This privacy notice informs you about the purposes and scope of processing your User Data, as well as data transfers, and your extensive rights. As our offer is exclusively aimed at persons with diabetes, your use typically already provides information on your health condition. We therefore only process User Data as health data with your consent. We differentiate as follows:

1.2.1.1 “Necessary Processing” describes how we process the User Data required to fulfil the contract. Without this consent the use of our products is not possible from a legal and a factual point of view because our services depend on this processing.

1.2.1.2 “Processing for Product Improvement” explains how you can help us and other users, with your consent, by allowing us to use your data to improve algorithms for therapy management, improve the product and so forth without us contacting you.

1.2.1.3 “Processing for Marketing Purposes” describes how we contact you for marketing purposes, with your consent, e.g., by email, notifications etc.

1.2.1.4 In “General Information” we have assembled the information that applies to all the above consents to avoid repetition.

The relevant categories are described in more detail below. You must provide the relevant consent upon registration or when ordering your product.

1.2.2 In some cases, the processing may take place independently of consent based on statutory principles (e.g., medical device regulations).

2. NECESSARY PROCESSING

If you grant your consent, we process the User Data listed below to be able to provide our services. If you do not consent to this necessary processing, you cannot use the services of AIAPS France. You may provide your consents during the registration process or when ordering your product.

2.1. Necessary User Data

2.1.1 In order to protect your User Data, our services can only be used in connection with a user account. To create a user account, we require and process the following User Data:

Email address
Password (we only save a checksum)
Name
VAT exemption declaration (name, address, date)
Year of birth
Registration date
Status of consent
Device ID, manufacturer, device type, operating system version, app version Language, country, time zone.

2.1.2 Other information collected outside a user registration include:

Medical Master Data

Weight, blood glucose target range, pump basal settings, correction factors, carbs/insulin ratio, insulin action duration, target glucose, alert settings, bolus step, carbohydrate unit.

Usage and Linkage Data

Pump and transmitter serial number, pump, sensor, and closed-loop/open-loop actions trail, app command-flow trail, event trail, followers’ information as entered into the app (phone number, credentials of diabetes data portal accounts), support queries, trainer details.

Medical Data

App entries such as date/time/time zone/place, food intake/meal, blood and sensor glucose measurements, sensor glucose rate of change, total daily insulin dose, insulin delivery (bolus and basal), temporary basal rate, closed-loop status, pump, and cannula priming, alerts, boost and ease-off events, app settings such as display options, statistical summaries of glucose and insulin data.

2.1.3 If you wish, you can enter any email address that you set up especially for us – however it must work so that we can send you important warnings.

We only process the User Data that you actively and voluntarily provide to AIAPS France, or which are obtained from glucose sensor and insulin pump you voluntarily connect to. The entry of necessary User Data is however a requirement for the comprehensive use of our products.

2.2. Necessary purposes

2.2.1 All the necessary purposes of our processing are associated with providing our services:

Customer enquiry leads to contact details data recordings.

Ordering of our apps by self-funders leads to contact details and technical data recordings such as device ID.

Installation of our apps leads to technical and device-related data recordings.

Registration leads to the creation of your AIAPS France account using the email address and password.

The provision of our services requires you to voluntarily and actively enter or provide data and each function describes the purpose for which the data is needed.

Communication from AIAPS France or distributor with you within our apps or via other electronic messaging services (e.g., email, messenger, telephone) where this is required to support or troubleshoot our products. This is how we process any comments and queries that you may have via various communication channels when using AIAPS France. The most important example is our support service, which you can access at info@aiaps.tech. Please therefore think about which information and data you want to give in your active communication with us - this is solely your decision. For our part, communication with users may be necessary by email or similar. This is how we inform you about updates to our products and provide important security advice as well as assistance associated with your usage. This support communication - as an essential part of our products - is sent to users.

Therapy devices (e.g., glucose sensor and insulin pumps) are paired with your device which enables data to be transferred to our apps.

2.2.2 Use of our apps requires you to actively and voluntarily enter or provide data. To resolve an error in the app we require, for example, crash reports that we can use for troubleshooting purposes to determine the circumstances of the problem. In addition, the key data of your device and your usage behavior are recorded as our contractual fulfilment, above all, means customizing our products i.e., processing individual user information, for example, depending on your location (also relevant for the search function). An automated analysis of user behavior is performed exclusively for the purpose of customizing your use when fulfilling the contract and has no legal effect for you.

3. PROCESSING FOR PRODUCT IMPROVEMENT

We also process your User Data beyond the necessary usage described in section 2 above to improve our products and services as described in more detail below.

3.1. Additional data

In general, we use the same User Data to improve our products as stated in section 2. In addition, AIAPS France may also record the following User Data:

Usage Data

Activity events that allow us to understand how you use our products. This enables us to see how our products are used and for example where menu designs can be optimized.

3.2. Purpose of product improvement

As a result of fast-moving technological progress, we must continually analyze, develop, test, and improve our products and their interactions, to ensure that our content benefits users in the most effective way. To achieve this, we may conduct usage, feasibility, predictive, control and security assessments and the knowledge gained is incorporated into improved new versions of our products such as the app. These improvements are also provided to you via regular updates.

4. PROCESSING FOR MARKETING PURPOSES

4.1. Newsletter

4.1.1 We may send you information on products and services in addition to the contractual scope (including information from carefully selected partners) and invitations to participate in surveys or other sales promotions and marketing activities (“Newsletter”).

4.1.2 You can select whether you want to subscribe to our Newsletter (opt-in). You can revoke your consent at any time in account settings.

4.2. Other types of marketing

4.2.1 Other consents, e.g., for surveys, notifications, or customized offers, are obtained as required. We always explain to you why we need certain data and how you can revoke the consent.

4.2.2 Please be aware that we may show you offers within the app without processing your personal data. You will also see these no customized advertisements if you have not provided your consent.

5. USAGE FOR STATUTORY PURPOSES

5.1. Scientific research and statistics

AIAPS France is committed to the science of all aspects of diabetes. Therefore, anonymous User Data may also be used for the purposes of research and statistics (always whilst complying with the recognized ethical scientific standards) and internal analyses. This is used mainly to determine and improve the effectiveness of techniques for controlling and treating diabetes.

5.2. Enforcement of rights

The use of personal data may also be necessary to prevent abuse by users or to assert, exercise, or defend legal claims. We may be forced into disclosure due to binding laws, court or official decisions and instructions, criminal investigation, or in the public interest. In such cases, the storage and processing of your data are permitted by law without your consent.

5.3. In accordance with medical device legislation

Finally, as the manufacturer or distributor of a medical device, we are subject to increased requirements for monitoring the functionality of our product. This vigilance system required for regulatory purposes may also involve the processing of personal data. The legal basis for this is Article 9 (2) I) GDPR.

6. GENERAL INFORMATION

6.1. Purpose limitation and security

6.1.1 AIAPS France uses your personal data exclusively for the purposes determined in this privacy notice and the relevant consents. We ensure that each processing is restricted to the extent necessary for its purpose.

6.1.2 Each processing always guarantees adequate security and confidentiality of your personal data. This covers protection from unauthorized and illegal processing, unintentional loss, unintentional destruction, or damage using appropriate technical and organizational measures. We use strict internal processes, security features, and encryption methods.

6.2. Processors

6.2.1 Our products are subject to complex processes that we have to manage and keep up to date. For technical support we may use third-party suppliers (“Processors”) to offer you a comprehensive and optimal use of our products.

6.2.2 AIAPS France transfers User Data to Processors exclusively within the framework of this privacy notice and only to fulfil the purposes stated in it. Processors work according to our specifications and instructions; they are not permitted to use the personal data of our users for their own or other purposes.

6.2.3 We use Processors offering sufficient guarantees that suitable technical and organizational measures are undertaken in a way that the processing of personal data complies with the statutory requirements and our privacy notice. The protection of the rights of our users is ensured by concluding binding contracts that meet the strict requirements of GDPR.

6.3. Encryption, pseudonymization, and anonymization

6.3.1 Each data transfer, without exception and by default, is encrypted during transfer. Using HTTPS (hypertext transfer protocol secure) or similar we ensure that your data is not intercepted by unauthorized third parties.

In addition, for the purposes of data security and minimization, we also use other processes for the encryption and pseudonymization of User Data. Of course, this depends on the type, scope, and purpose of the relevant data processing. For example, we only disclose User Data that a Processor requires to carry out his tasks.

6.3.2 When a contractual relationship with a Processor is terminated, such Processor must, at AIAPS France’s discretion, either return all our User’s Data or delete it if there are no statutory storage obligations.

6.3.3 Data that requires no personal reference for processing (e.g., for research and analysis) is subject to anonymization. This prevents a connection to a specific user being made in all cases

6.4. EU and other countries

6.4.1 We seek to select cooperation partners who are based in or whose servers are in the European Union (EU) or European Economic Area (EEA). Data transmission within the EU and EEA is unobjectionable because the GDPR applies in all member states.

6.4.2 In exceptional circumstances we appoint third-party suppliers who are in or who have servers outside the EU. However, even in these cases your personal data is subject to a high protection level in line with the GDPR – either through an EU adequacy decision, which considers data protection in certain third-party countries to be appropriate (e.g., Switzerland, Israel, and New Zealand), or through certain standard contractual clauses approved by the EU, which the contractual relationships with our contracted data processors are based on, or through comparable legal instruments permitted under the GDPR.

6.4.3 In addition, we ensure that our partners have additional security standards in place, such as individual security measures and data protection provisions or certifications under the GDPR. So, for example, if third-party suppliers are located in the USA, they should be subject to the Privacy Shield Framework approved by the EU or comparable internationally recognized security standards.

6.5. Cookies

AIAPS France may store so-called “cookies” to offer you a comprehensive range of functions and make the use of our website more convenient. Cookies are small text files that are stored on your device by your browser. Except for the cookies for usage data mentioned in section 6.6, our cookies may be used to operate the website. If you do not want to use cookies you can prevent them from being stored using the relevant settings in the browser. Most of our cookies are either deleted at the end of your visit or when the browser is closed (session cookies). If this is not the case, you can check the deletion period in your browser or delete the cookies manually.

6.6. Usage data

We use Google Firebase Analytics in the app, an app and web analysis service by Google Inc. (“Google”). Google is certified under the EU-US Privacy Shield.

6.7. Storage and deletion

6.7.1 Your User Data is stored on your device. This data is also stored on servers. We only use systems that meet GDPR requirements.

6.7.2 Your data are stored on servers in the European Union (EU).

6.7.3 As a rule, AIAPS France only stores your personal data for the duration of the contract. In exceptional cases, longer storage may be required to fulfil post-contractual obligations or to comply with statutory storage obligations or disclosure duties, or to assert, exercise, or defend legal claims (limitation periods).

6.8. Minors

Minors, below the age of sixteen are only permitted to use our products with the consent of a parent/guardian General Terms ad Conditions - T&Cs. This also applies to processing their personal data, which is only legal if and to the extent to which the consent has been obtained by and through the parent/guardian. Otherwise, use of our products is prohibited.

6.9. Data protection officer

6.9.1 Our data protection officer is available to answer all data protection questions at info@aiaps.tech.

6.9.2 The data protection officer is widely involved in all questions associated with protecting the personal data of our users. As a trained expert, she/he monitors our processing on an ongoing basis to ensure the best possible protection of your User Data.

7. YOUR RIGHTS

7.1. Revocation of consents

If we process your User Data based on your consent, you may revoke the consent at any time. However, this will not affect the lawfulness of the processing before the revocation. We will continue to provide our services if they do not depend on the consent that has been revoked.

7.2. Information, correction, and restriction

7.2.1 Each user has the right to request information on the processing of their personal data. To do so, please contact us at any time at info@aiaps.tech.

7.2.2 Your right to information covers information on the processing purposes, data and recipient categories, storage time, origin of your data, and your rights under the data protection regulations. You can find all of this information in this privacy notice and we are happy to provide it to you in an electronic form.

7.2.3 Should some of your personal data be incorrect, you can request that your data is corrected or completed at any time. You have the right to restrict data processing for the duration of any investigation review that you have requested.

7.3. Deletion (“right to be forgotten”)

Each user has the right to request the deletion of their personal data. To do so, please contact us at any time at info@aiaps.tech.

7.4. Complaints

7.4.1 If you feel we are not protecting your data protection rights adequately, please contact us at any time at info@aiaps.tech or contact our data protection officer directly at info@aiaps.tech We will handle your request appropriately.

7.4.2 Any user has the right to submit a complaint with the appropriate Data Protection Authority responsible for AIAPS France if they believe that the processing of their personal data is not in compliance with data protection regulations. In addition, the user has a right to complain to a supervisory authority in the EU member state in which they are resident, in which their workplace is located, or which is the location of a suspected infringement.

AI APS is a registered trademark of AIAPS France Ltd. Other trademarks are the property of their respective owners. No use of any AIAPS France trademark, trade name, or trade dress in this site may be made without the prior written authorization of AIAPS France, except to identify the product or services of the company. The product images are for illustrative purposes only.

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