Effective Date: February 24, 2020
What information we collect;
With whom it is shared;
How it may be corrected;
How it is secured;
How policy changes will be communicated; and
How to address questions about our use of Personal Information.
1. Information Collection, Use, and Sharing
We only have access to or collect information that you voluntarily give us via direct contact from you, or via your use of the DIANAVI App. “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural human person or, in some instances, household. We will not sell or lease this information to anyone.
A. Information We Collect From You
Registration Information: In order to use the DIANAVI App, you must complete a registration form. During registration, you are required to give certain Personal Information (such as name and email address). You also are required to provide certain demographic Personal Information (such as gender, age, and race) about yourself so that we can accurately analyze and provide the appropriate products and services to you. The DIANAVI App will also ask if you want to turn on location services during the registration process. If you agree to this, we will collect information about your exact or approximate location. You may turn off location services at any time by disabling the use of location services in your device’s settings menu. When registering for an account you will also be requested to provide other information such as diabetes type, height, and weight. The scope of the Personal Information collected by DIANAVI depends on your use of the DIANAVI App. Active data entry is a requirement for comprehensive use of the DIANAVI App.
Optional Information: Certain information (some of which may be Personal Information), such as insulin therapy (pen/pump), meter/therapy device, type of insulin, activity and meal logs, injection times, blood glucose measurements, steps, among others, is optional and you are not required to provide this to us. If you do not enter optional data such as this, the associated functionality of the DIANAVI App is limited accordingly. For example, our Logbook feature requires voluntary entry of your data for optimal use. In addition to the entries you provide voluntarily, there is also the option to independently activate or deactivate the recording of certain data in the settings of the DIANAVI App and other software of your device (e.g., operating system, other apps, app stores, etc.).
From time-to-time, we request information on the DIANAVI App via surveys. Participation in these surveys is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Contact information may be used to notify the survey participants. Survey information will be used for purposes of monitoring or improving the use and satisfaction of the DIANAVI App.
B. Automatically Collected Usage and Device Information
Similar to other websites and applications, we use tracking technologies to automatically collect certain technical information from your web browser, mobile, or other device when you visit the DIANAVI App. This data may include, without limitation, your IP address, browser type and language, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of your visits. Our collection of this data allows us to provide more personalized services to you and to track usage of the DIANAVI App.
We use “cookies” on the DIANAVI App. A cookie is a piece of data stored on a DIANAVI App user’s hard drive to help us improve your access to the DIANAVI App and identify repeat visitors. For instance, when we use a cookie to identify you, you may not have to log in with a password more than once, thereby saving time while on the DIANAVI App. Cookies can also enable us to track and target the interests of our users to enhance their experience on the DIANAVI App.
C. Information from Other Sources
We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to your account information or other information we have collected. Any information acquired from a third party application is protected within the DIANAVI App like any other data. Some examples of third party data that we may acquire with user permission includes, but is not limited to:
D. How We Use Your Personal Data
We will use and process your Personal Information to provide you with certain services, such as to:
Help you understand patterns and trends in your data.
Send you coaching notifications.
Understand where coaching may be most applicable.
Create a report of your Personal Information. You may use the DIANAVI App’s functions to export such report by email, or provide it to third parties such as doctors, medical providers, or other people of your choice. Please be sure that you are only sharing your Personal Information with intended parties. Any sharing of your Personal Information is at your own risk, and DIANAVI is not responsible for protecting the information you share with other parties via the DIANAVI App. Please be cautious when sharing your Personal Information.
We will use and process your Personal Information for the following business purposes:
To perform internal analysis to determine how we can make a more effective DIANAVI App experience for users.
To conduct data analysis, testing, research, and statistical analysis.
To develop and implement security controls and mechanisms within the DIANAVI App.
To fulfill or meet the reason you provided the information (e.g., to provide you with reports).
To provide certain features or functionalities on the DIANAVI App.
To create, maintain, and customize your account with us.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To prevent illegal activity, fraud, and abuse.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users is among the assets transferred or liquidated.
We will use non-personally identifiable information, such as anonymized and/or aggregated usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the DIANAVI App, including to create reports for internal use and to customize the DIANAVI App in a way that is more useful and interesting to users. For example, we may track the use of different features within the DIANAVI App. Any non-personally identifiable information that is combined with Personal Information will be treated by us as Personal Information.
2. Access to Profile Information
Your Personal Information in your account on the DIANAVI App will be viewable to anyone who has been granted access to your account. Your Personal Information will not be viewable by other users of the DIANAVI App.
The DIANAVI App contains links to other websites. Please be aware that we are not responsible for the content or privacy practices of such other websites. We encourage our users to be aware when they leave the DIANAVI App and to read the privacy statements of any other website that collects Personal Information.
4. Your Access to and Control over Information
You may opt-out of future contact from us at any time. Please remember that even if you opt out of receiving marketing e-mails, we may still send you important service information related to your account and the DIANAVI App. If you correspond with us by email, we may retain the content of your email messages, your email address, and our responses. You may have the right to do any of the following by contacting us via the contact form provided in the DIANAVI App:
See what Personal Information we have about you, if any.
Change/correct any Personal Information we have about you.
Have us delete any Personal Information we have about you or your account.
Submit any feedback you have about our use of your Personal Information.
5. Children’s Privacy
By establishing an account with us, purchasing any goods or services through the DIANAVI App, submitting any information to us, or otherwise using the DIANAVI App, you are representing and warranting that you are at least 18 years of age (or that you are at least 13 years of age and have your parents’ permission to establish an account, make a purchase, submit information or otherwise use the DIANAVI App, as applicable).
The DIANAVI App is designed to give you coaching and insights related to diabetes, so you can understand how your lifestyle may affect your diabetes. The DIANAVI App requires WiFi and/or data connectivity for syncing and retrieving Personal Information. The DIANAVI App is designed to assist with the management of your diabetes, but the DIANAVI App is not a substitute for medical advice. Always seek medical advice from your healthcare provider regarding your diabetes. DIANAVI does not provide medical advice to users. Contact your healthcare provider or emergency services if you suspect you have a medical emergency.
If you use parts of the DIANAVI App that relate to services provided by a medical professional or that are covered by an insurance provider, you may be asked to submit personal medical and health information, insurance information, as well as demographic and other information relevant to diagnosis and treatment, such as lifestyle and general medical history (e.g., conditions, allergies, etc.) (collectively, “Medical Information”). With your consent, DIANAVI will share your Medical Information via confidential channels to a doctor, other medical professional, or insurance provider regarding your diagnosis and treatment.
Any Medical Information that you submit may be covered by HIPAA, which offers different protections for Medical Information than privacy laws such as the California Consumer Privacy Act (CCPA). To the extent that any Medical Information that you submit to us is subject to HIPAA protection, such Medical Information will be handled in accordance with HIPAA requirements.
We take precautions to protect your Personal Information. We use certain physical, managerial, and technical safeguards designed to preserve the security of the Personal Information and other information we maintain in connection with your use of the DIANAVI App. When you submit Personal Information via the DIANAVI App, your Personal Information is protected both online and offline. Wherever we collect Personal Information (such as Medical Information), that information is encrypted and transmitted to us in a secure way. You also play a part in protecting your own Personal Information, so we recommend having a passcode to lock your phone and a DIANAVI account password that is strong and unique.
While we use encryption to protect sensitive information transmitted online and via the DIANAVI App, we also protect your information offline. Only employees who need the information to perform a specific job (e.g., customer service) are granted access to Personal Information. The computers/servers on which we store Personal Information are kept in a secure environment. While these measures are helpful to safeguard your Personal Information after we receive it, no transmission of data over the internet can be guaranteed to be 100% secure.
8. Notification of Changes
9. Notification to Users outside the United States
Please be aware that we are headquartered in the United States. The DIANAVI App is governed by United States law. If you are using any of our products or services from outside of the United States, your information may be transferred to, stored, and processed in the United States where our servers may be located. The United States might not offer the same level of privacy protection as the country where you reside or are a citizen. BY USING THE DIANAVI APP, COMMUNICATING WITH US VIA MAIL, EMAIL OR TELEPHONE, OR OTHERWISE PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO, AND PROCESSING OF, YOUR INFORMATION IN THE UNITED STATES.
10. Other Provisions and Laws
A. “Do Not Track”
Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have the user’s online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about that browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website and application operators, including the DIANAVI App, do not respond to DNT signals.
B. California Shine the Light Law
California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed Personal Information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to email@example.com.
C. The General Data Protection Regulation (“GDPR”)
Residents of the European Economic Area (“EEA”) may be entitled to rights under the GDPR. If you qualify, these rights are summarized below.
If you request to exercise your rights under the GDPR, we may require verification of your identity before we respond to any such request. If you are entitled to these rights, you may exercise your rights with respect to the Personal Information that we collect and store:
the right to withdraw consent to data processing at any time;
the right of access to your Personal Information;
the right to request a copy of your Personal Information;
the right to correct any inaccuracies in t your Personal Information;
the right to erase your Personal Information;
the right to data portability, meaning to request a transfer of your Personal Information from us to any other person or entity as chosen by you;
the right to request restriction of the processing of your Personal Information; and
the right to object to processing of your Personal Information.
You may exercise these rights free of charge. These rights will be exercisable subject to limitations as provided for by the GDPR. Any requests to exercise the above-listed rights may be made to: firstname.lastname@example.org. If you are an EEA resident, you have the right to lodge a complaint with a Data Protection Authority about how we process your Personal Information at the following website: https://edpb.europa.eu/about-edpb/board/members_en.
For further information, inquiries or assistance you may contact DIANAVI at the address, email address, or telephone number listed below. Customer service is available as specified in the DIANAVI App. The channels for support might differ from time-to-time.
19772 MacArthur Blvd, Suite 110
Irvine, CA 92612
+1 (888) 680 - 9082