Version 1.1
Privacy Policy for MedM Mobile Applications
Last updated: October 24, 2023
MedM Inc. and its affiliates ("MedM", “The Company”, "we," "our" or "us") is committed to protecting the privacy, integrity and security of any personal information of our users.
This Privacy Policy (the “Policy”) describes how The Company collects, uses and shares the data you may provide by using the services available on this Website https://health.medm.com (the “Site”), the services available via our applications Blood Sugar Diary, Health Diary, MedM Care, Blood Pressure Diary, Temperature Diary, and Smart Weight Diary (the “Software”), the newsletters, the electronic messages and announcements (“Electronic Communications”). All such services, collectively, are defined as the “Service”.
Any personal information you provide to us while using the Service will be treated with care, subject to this Policy, and will not be used or disclosed in ways in which you have not consented except as indicated below.
By using our Service, you hereby consent to the collection, use, and disclosure of your personal information in accordance with this Policy. If you do not agree to this Policy you may not use the Service and should remove all copies of the Software you have immediately.
This Policy is a subject to the provisions of our Terms of Use incorporated by the reference.
1. Information we collect
1.1. Registration information
The first time you sign in to the Service via the Site or the Software the Service asks you to create a Service account (the “Account”). To create a Service account you must provide personal information such as name and e-mail address and specify a password.
You also may use the Software in offline mode (the “Local Mode”) without connecting to the Site. In this case the Account registration is not needed and your data isn’t stored on the Site.
1.2. Feature specific personal data
Depending on the features you use you may be asked for additional information such as birth date, gender information, your height, and your fitness goals.
This data is used for calculation of other parameters such as body composition values, burned calories count as well as to evaluate your progress in the goal achieving.
1.3. Standard information
We also collect standard information about our users such as IP addresses, browser type, operating system, pages visited on our site, referring and exit pages, and the dates and times of the visits. This site visitation data is used to administrate the site and provide general statistics regarding the use of https://health.medm.com . Site visitation data is never linked to your personal information and we do not use it to identify you individually.
1.4. Health, wellness and fitness information
The Service allows you to manage one or more health records, such as the ones you create for yourself and your family members. You can add different kinds of information either entered manually or collected automatically from the Sensors compatible with the Service, or from Google Fit.
You choose what information to put in your records. Examples of the types of information you can store in a record include:
- measurements such as blood glucose, blood pressure, body weight or heart rate entered manually via the Software or the Site or collected automatically by the Software from the Sensors;
- data imported from Google Fit: Blood Glucose, Activity, Blood pressure, Heart rate, Body temperature, Oxygen saturation, Sleep;
- personal text notes;
- images and scanned documents.
1.5. Information that we collect from you about others
If you decide to invite a third party to use the Service we will collect such third party’s name and e-mail address so that we may send such third party an invitation to use the Service and other information about the Service. If you decide to use our Service with the social networking platforms we may collect information about your interactions with the people to whom you associate through those platforms.
1.6. Contact information
When you need any help from our customer services you may need to provide your contact information such as your name, e-mail address, telephone or mobile number, postal address and order details. Your contact information will not be distributed to any third parties.
1.7. Non-Identifiable Information
The Service may automatically collect certain non-identifiable information regarding the Service users such as the serial number of your personal digital assistant or mobile device (i.e. iPhone, iPod Touch, iPad, Android or Windows device). Your non-identifiable information may be disclosed to others and permanently archived for future use. The Company also may link your non-identifiable information with other Software users’ personal information. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Policy, and in accordance with applicable law.
1.8. Account settings information
To configure your Account you may set different Service settings such as preferred type of units, measurement types you’d like to track, or threshold values and notification parameters for Health Records you have access to.
1.9. Other information we collect
To improve the Service we also collect the information of how you interact with our services, including the browser you're using, your IP address, your location, cookies or other unique IDs, the pages you visit and the features you use. We combine this with other users' information to get an overall view of how the Service are used.
2. How we use information
2.1. Communicating with you
We use your information collected through the Account including health information to provide the Service, and as described in this privacy statement. We do not use or disclose your information except as described in this privacy statement.
The Company may use personal information:
- to send you the Service sign up notification or message requesting e-mail validation;
- to notify you about the suspicious activity such as accessing the service from unusual IP address or any unusual activity happening with your Account;
- to provide you with the important information about the Service including critical updates and new major releases;
- to send you the Company e-mail newsletter if you opt-in;
- to determine your age and location to check if you qualify for an account or to choose the display language.
2.2. Communication with others
Your e-mail is included to the data sharing invitations you send via the Service to identify you to the invited person.
2.3. Using of third-party services
The Company occasionally hires other companies to provide limited services on our behalf such as answering customer questions about products and services. We give those companies only the personal information they need to deliver the service, such as IP address or e-mail address. The Company requires the companies to maintain the confidentiality of the information and prohibits them using the information for any other purposes.
2.4. Information disclosing due to the legal compliance
The Company may access and/or disclose your personal information if we believe such action is necessary to: (a) comply with the law or respond to legal process served on the Company; or (b) protect the rights or property of the Company (including the enforcement of our agreements).
Personal and health information stored in the Service may be processed in the United States or any other country in which the Company or its affiliates, subsidiaries or service providers maintain facilities.
2.5. Use of cookies
We use cookies with the Service to enable you to sign in and to help to personalize the Service. A cookie is a small text file that a web server places on your hard disk. It is not possible to use cookies to run programs or deliver viruses to your computer. A Web server assigns cookies uniquely to you and only a Web server in the domain that issued the cookie to you can read the cookies.
One of the primary purposes of cookies is to provide a convenient feature to save you time. For example, if you personalize a Web page or navigate within a site a cookie helps the site to recall your specific information on subsequent visits. Using cookies simplifies the process of delivering relevant content, eases site navigation, and so on. When you return to the Web site, you can retrieve the information you previously provided, so you can easily use the site's features that you have customized.
You have the ability to accept or decline cookies. Most of Web browsers automatically accept cookies, but you can usually modify your browser setting to decline some or all cookies if you prefer. If you choose to decline all cookies, you may not be able to use the interactive features of this or other Web sites that depend on cookies.
2.6. How we use aggregated information and statistics
The Company may use aggregated information from the Service to improve the quality of the Service and for marketing of the Service (for example, to tell potential advertisers how many Service users live in the United States or Europe). This aggregated information is not associated with any individual account. The Company does not use your individual Account and record information from the Service for marketing without the Company first asking for and receiving your opt-in consent.
3. How information is shared
By default, you are the custodian of the records you create. You may invite additional people to be custodians. Each custodian can add and remove other custodians and users who can view and modify the record. Some of the information stored in the records you manage may be highly sensitive, so you need to consider carefully with whom you choose to share the information. A record may have multiple custodians.
A key value of the Service is the ability to share your health information with the people who can help you to meet your health-related goals. For example, you can share health information from records you control:
- to co-manage the health of a family member
- to use it with other health-related products and services
- to consult with your health care provider
- to provide fitness information to coaches and trainers.
You can share information in a health record you are custodian of with another person by sending a sharing invitation e-mail via the Service. If the person accepts your sharing invitation and has or creates the Service account, you grant him or her access to that information. You can revoke view and read access anytime and can revoke a custodian access once invitation is accepted.
You can also choose to grant custodian access to other persons, such as your spouse, for any record of which you are a custodian. The custodian access is the highest level of access, so you should think carefully before you grant the custodian access to a record. A custodian can also revoke access to a record from any other user having the access to this record, including you.
The level of access you can grant as a custodian include:
- view-only access (time-limited access)
- view-and-modify access (time-limited access)
- custodian access (no time limit).
Access becomes active only when the recipient accepts the invitation.
A custodian of a health record can:
- read the record
- change the record
- delete the record
- grant to others any level of access to the record, including custodian access.
Because inappropriate granting of access could allow a grantee to violate your privacy or even revoke your access to your own records (in case of granting custodian access), we urge you to consider all the consequences carefully before you grant access to your records.
4. Your rights to access and control your personal data
4.1. Accessing and exporting data.
By logging into your account, you can access much of your personal information, including your dashboard with your recent measurements data and activity statistics. Using export section of the Site, you can also download information in a commonly used file format, including data about your activities and measurements history.
4.2. Editing and deleting data.
Your account settings let you change and delete your personal information. For instance, you can edit or delete the profile data you provide and delete your account if you wish.
If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like the data recorded by you and other data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm as described in the How information is shared section.
4.3. Objecting to data use.
The Service provide you with settings and tools to control our data use. For example, through your sharing settings you can limit how your information is visible to other users of the Service; using your notification settings you can limit the notifications you receive from the Service; using Care Circles you can subscribe and unsubscribe to access data from other users sharing their data with you.
If you live in a jurisdiction of EU GDPR Country, in certain circumstances, you can object to our processing of your information based on our legitimate interests, including as described in the How We Use Information section. You have a general right to object to the use of your information for direct marketing purposes. Please see your notification settings to control our marketing communications to you about the Company products. Please also review our Use of cookies statement for your options to control how we and our partners use cookies and similar technologies for advertising.
4.4. Restricting or limiting data use.
In addition to the various controls that we offer, if you reside in a jurisdiction of EU GDPR Country, you can seek to restrict our processing of your data in certain circumstances. Please note that you can delete your account anytime.
If you need further assistance regarding your rights please contact our Data Protection Officer at privacy@medm.com and we will consider your request in accordance with applicable laws.
5. Data retention
We keep your account information like your name, e-mail address, and password, for as long as your account is in existence because we need it to operate your account. In some cases when you give us information for a feature of the Service we delete the data after it is no longer needed for the feature. For instance, when you provide your contact list for finding friends on the Service, we delete the list after it is used for adding contacts as friends. We keep other information, like your measurements results or activity data, until you use your account settings or tools to delete the data or your account because we use this data to provide you with your personal statistics and other aspects of the Service. We also keep information about you and your use of the Service for as long as it is necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the How we use information and How information is shared sections.
6. Analytics and advertising services provided by others
We work with partners who provide us with analytics and advertising services. This includes helping us to understand how users interact with the Service, serving ads on our behalf across the Internet, and measuring the performance of those ads. These companies may use cookies and similar technologies to collect information about your interactions with the Service and other websites and applications. To learn more and about your privacy choices, please read our Use of cookies statement.
7. Our policies for children
Children under the age of thirteen (13), or any higher minimum age (sixteen (16) for the jurisdictions covered by EU GDPR) in the jurisdiction where that children resides, are not permitted to create accounts unless their parent has consented in accordance with applicable law. If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at privacy@medm.com.
8. Information security
MedM continuously evaluates our security posture to further enhance the security of user data. A combination of technical, administrative, and physical controls are employed to maintain the security of personal information. Data transfers from Software to the Site are processed through secure connections. Sensitive user data is stored encrypted to safeguard against unauthorised or unlawful access. The use of information received from Health Connect adheres to the Health Connect Permissions Policy, including the Limited Use requirements.
However, no method of transmitting or storing data is completely secure, and should you have a security-related concern, please contact our customer support at support@medm.com.
9. Our international operations and data transfers
We operate internationally and transfer information to the United States and other countries for the purposes described in this Policy.
10. Changes to this policy
This Policy may be changed by the Company from time to time in the Company’s sole discretion. You will be notified of changes to this privacy policy by the Company issuing an update or new version of the Software. Upon installing the update or new version of the Software you will be asked to review and agree to the new privacy policy. The Company shall bear no liability for any loss, damage or expense arising directly or indirectly, from amendments to this Policy. The collection, use and disclosure of your personal information by the Company will be governed by the latest version of this Policy. New versions of this Policy will be posted at Privacy Policy subsequent to any changes to this Policy will signify that you consent to the collection, use and disclosure of your personal information in accordance with the changed Policy. Accordingly, when you use the Software or receive or request any Electronic Communication, you should check the date of this Policy and review any changes since the last version. You should also bookmark this page and periodically review this Policy to ensure that you are familiar with the most recent version.
11. How to contact us
If you have questions, suggestions, or concerns about this policy, or about our use of your information, please contact us at privacy@medm.com.
MedM, Inc
Attn: Legal Department (Privacy Policy)
702 San Conrado Terrace, Unit 1
Sunnyvale
CA 94085-2509
USA
MedM EU Representative
Attn: Denis Khitrov
Erthalstraße 12
63739 Aschaffenburg
Germany