Privacy Policy
PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.
KLUE PRIVACY STATEMENT
STATE-SPECIFIC PRIVACY NOTICES

INTRODUCTION

Welcome to Klue, Inc. a wholly owned subsidiary of Medtronic MiniMed, Inc. (“Klue”). Privacy is very important to us. We also understand that privacy is very important to you. This Privacy Statement tells you how we protect and use information that we gather in connection with (i) your use and/or access to the www.goklue.com website; (ii) your use of and/or access to the Klue™ Health App (“App”); (iii) your use of and/or access to the Klue software to connect third-party wearable devices (“Software”) and (iv) your use of and/or access to any content or information and other wearable/mobile-enabled or online technology, digital tools and other services, software and products provided by us, including confidential materials, services, products, and features (including any related components, accessories, and documentation) currently under development by Klue based in the United States (collectively “Klue Services”). Klue and its affiliates, including Medtronic MiniMed, Inc. and our international affiliates, also operate other websites. This Privacy Statement does not apply to those other websites unless specifically indicated otherwise. You should review the privacy statement posted on other Medtronic websites when you visit them. The Klue Services and this Privacy Statement are intended for a U.S. audience.

By using Klue Services, you agree to the terms of the most recent version of this Privacy Statement. Please read our Terms of Use to understand the general rules about your use of Klue Services. Except as written in any other disclaimers, policies, terms of use, or other notices on this website or the App, this Privacy Statement and the Terms of Use are the complete agreement between you and Klue with respect to your use of Klue Services. You may be subject to additional terms that may apply when you access specific services or materials on certain areas in this website, or when you follow a link from this website.

WHAT DO WE DO WITH NON-PERSONAL INFORMATION?

Non-personal information is information that cannot identify you or be tied to you. We are always looking for ways to better serve you and improve this website. We will use non-personal information from you to help us make this website more useful to visitors. We also will use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information:

  • for internal use to develop programs, products, services or content
  • to customize the information or services that are of interest to you
  • share it with affiliates or third parties
  • provide aggregated information on how visitors use our site, such as 'traffic statistics' and 'response rates,' to third parties

WHAT IS PERSONAL INFORMATION?

Personal information is information that we can use to specifically identify you, such as your:

  • Name
  • Address
  • Unique personal identifier (e.g., device ID, online identifier)
  • Internet Protocol address
  • Email address
  • Account and profile name
  • Social security number
  • Driver’s license number, or
  • Other similar identifiers
  • Characteristics of protected classifications under state/federal law (e.g., age, race, sex, medical condition, etc.)
  • Medical information
  • Health insurance information
  • Financial information, including credit card numbers
  • Biometric information (e.g., imagery of the iris, retina, fingerprint, face, or other data that contain identifying information)
  • Commercial information (e.g., purchase history)
  • Internet or other electronic network activity information (e.g., browsing history, interaction with our website, etc.)
  • Geolocation and motion-related data
  • Audio, electronic, visual, thermal, olfactory, or similar information (e.g., call recordings)
  • Professional, employment-related, or other similar information

HOW DO WE KEEP AND USE PERSONAL INFORMATION?

We may keep and use personal information we collect from you through Klue Services to provide you access to our services. In addition, we may keep and use your personal information:

  • to facilitate the creation and administration of your Klue Account and Profile
  • to send you notifications, support emails and a welcome e-mail
  • to respond to your requests
  • to request feedback and survey responses
  • to assist us in offering Klue services to you, including personalizing your access to Klue services, for example, by telling you about new features that may be of interest to you
  • to develop records, including records of your personal information
  • to contact you with information that might be of interest to you, including information about clinical trials and about products and services of ours and of others
  • for analytical purposes and to research, develop and improve programs, products, services and content
  • for U.S. healthcare providers, to link your name and/or your IP address to web pages you visit, for compliance, marketing, and sales activities
  • to remove your personal identifiers (your name, e-mail address, social security number, etc.). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information.
  • to enforce this Privacy Statement and other rules about your use of this website
  • to protect someone's health, safety or welfare
  • to protect our rights or property
  • to comply with a law or regulation, court order or other legal process
  • We may share personal information with any member of our corporate group, including parent companies, subsidiaries, and affiliates, and other companies in which we have an ownership or economic interest for purposes that are consistent with those identified in this Privacy Statement.

ELECTRONIC COMMUNICATIONS

In using Klue Services and registering for an Account, you may receive periodic communication from Klue. The communications between you and Klue use electronic means. Klue may occasionally communicate with you via e-mail, phone or Notifications on your mobile device. By using Klue Services, you (1) consent to receiving electronic communications from Klue; and (2) agree that all terms and conditions, agreements, notices, disclosures, and other communications that Klue provides to you electronically satisfy any legal requirement that such communications would satisfy if it were to be in writing.

DO WE EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

We will not share your personal information collected from this website with an unrelated third-party without your permission, except as otherwise provided in this Privacy Statement.

In the ordinary course of business, we will share some personal information with companies that we hire to perform services/functions on our behalf or provide Klue Services to users. For example, we may use different vendors or suppliers to support your use of Klue Services.  In cases in which we share your personal information with a third-party, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting website visitors who violate our rules or engage in behavior which is harmful to other visitors (or illegal).

We may disclose your personal information to third parties if that the disclosure is necessary to:

  • enforce this Privacy Statement and the other rules about your use of this website
  • protect our rights or property
  • protect someone's health, safety or welfare
  • fulfill obligations relating to a corporate sale, merger, dissolution, or acquisition
  • comply with a law or regulation, court order or other legal process

Please note: In addition to the ways that we may keep, disclose, and use information described in this Privacy Statement, we also may keep, disclose, and use personal information in ways that we believe are consistent with governmental guidance, directions, regulations, and laws, including HIPAA and FDA requirements, where applicable.

COLLECTING ELECTRONIC INFORMATION

If you visit our website to read or download information about one of our products or services, we may collect certain information about you from your computer. This information is collected from your computer's web browser. This information may include:

  • The name of the domain from which you access the Internet
  • The Internet Protocol address (“IP Address”) of the computer you are using
  • The type of browser and operating system you are using
  • The date and time you access our website
  • The internet address of the site from which you linked directly to our website
  • Which pages you have visited on our website
  • The search terms you use
  • The links on which you click

Cookies: We also may collect this information through cookies, pixels, web beacons, and similar technologies (“cookies”), that work through placing a small file (like a text file or graphic) in the browser files of your computer when you visit. The cookie may be stored on your computer's hard drive. Cookies are used to collect information for business purposes, such as enabling essential website functions and improving the user experience. We use both session cookies and persistent cookies. You are free to decline our cookies if your browser permits, but some parts of our website may not work properly for you if you do so. Klue may use third-party tracking and advertising providers to act on our behalf to track and analyze your usage of our sites. These third parties may collect, and share with us, as we may request, website usage information about visits to our sites, measure and research the effectiveness of our advertisements, and track page usage and paths followed during visits through our sites. Also, these third-party providers may place our Internet banner advertisements on other sites that you visit, and track use of our Internet banner advertisements and other links from our marketing partners' sites to our sites. To the extent the information collected on behalf of Klue by these third parties contains any personally identifiable information, we will protect it in accordance with this Privacy Statement.

We will not allow third parties other than those companies that we hire to perform services or functions on our behalf to place cookies on our website. Please refer to your browser Help instructions to learn more about managing cookies. And see below for an explanation of our use of cookies as well as how to opt out of our use of cookies.

CHOICES ABOUT COOKIES

For more information on third-party advertising-related cookies and how to opt out of some cookies as you choose, see the descriptions and links below.

You may opt-out of the use cookies through your internet browser’s plugins or privacy settings at any time, but this may impact the functionality of our website.

Click here to visit the Network Advertising Initiative site to set preferences and opt out of third-party targeting cookies

DEVICE INFORMATION

Klue Services require the use of a third-party wearable device. We collect personal information about your wearable device, such as the make and model, connection status, write preference, battery life, etc. We also collect personal information from your wearable device, which may include motion sensor data, heart rate, blood pressure, weight data, and temperature information. If you have enabled location services on your mobile device and/or your wearable device, we may also collect geolocation information to improve our App and services. We may also collect information, including historical information, from your mobile device or third-party applications through which you have granted access to your personal information, such as HealthKit.

We only collect information from your wearable device when you are logged into the Klue app. To stop the collection of device information, log out of the App on your mobile device. However, if you granted access to third party apps, we may collect historical data from such apps when you log back into your Klue account.

HOW DO WE PROTECT YOUR KLUE ACCOUNT INFORMATION?

To use Klue Services, you must register for an Account. We collect personal information from you when you register for an account to use Klue Services. To establish your Account, we collect your email address and password. Your email address will be your Klue account username, which you will use to log into your account. The information in this section applies to your account:

Personal Information Collected Through Your Profile. We collect personal information when you create a Klue Account profile (“Profile”). To establish your Profile, we may collect personal information you choose to provide us. We may also collect information about your health, lifestyle, and eating and drinking behaviors. You can choose not to provide us with certain personal information on your Profile, but please be aware that may restrict your access to certain Services and/or impact the Services provided to you.

Viewing/Editing Personal Information: You may change the information you have provided on your Profile by logging into your account and editing the information.

Storage of Personal Information: Klue, Medtronic Diabetes or their vendors providing services in connection with the Klue Services, may store your personal information on servers in countries where Medtronic Diabetes operates, including a server(s) located in the United States of America. If you choose to close your account, we will maintain copies of your information in our internal records, systems, and databases, in accordance with our data retention schedules. We will continue to treat your personal information in accordance with this Privacy Statement. 

Protecting Personal Information: We take security seriously and take a number of steps to protect your personal information. You also play a big part in protecting the privacy of your personal information. When you create an account, we ask you to select a password that is unique to you. To protect your personal information from unwanted disclosure, you should not give your password to anyone with whom you would not share your personal information. Our website may also log you out after a period of inactivity and require you to log in again. When you are ready to leave this website, always “log off” and close your browser to help protect the confidentiality of your information.

WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made. By continuing to use or access our website after those changes become effective, you agree to be bound by the revised Privacy Policy. Significant changes are also described below.

Recent revisions to the Privacy Statement:

This Privacy Statement was last revised  on May 14, 2020 following Medtronic’s acquisition of Klue, Inc. Click here to read Klue’s previous privacy policy.

WHAT ABOUT PRIVACY ON OTHER WEBSITES?

This website may contain links to other websites. Some of those websites may be operated by Klue or its affiliates, and some may be operated by third parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. We are not responsible for the performance of websites operated by third parties or for your business dealings with them. Therefore, whenever you leave this website, we recommend that you review each website's privacy practices and make your own conclusions regarding the adequacy of these practices.

DO WE EVER COMMUNICATE DIRECTLY WITH VISITORS TO THIS WEBSITE?

We may contact you periodically by e-mail, mail or telephone, if you agree to that method of contact, in order to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this website allow you to communicate with us using an online form. If your communication requests a response from us, we will send you a response via e-mail. The e-mail response or confirmation may include your personal information, including personal information about your health, your name, address, etc. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.

ARE THERE SPECIAL RULES ABOUT CHILDREN'S PRIVACY?

We care about protecting the online privacy of children. The Klue Health App is only available to users over the age of 18. We will not intentionally collect any personal information (such as a child's name or e-mail address) from children under the age of 13. If you have questions about a child’s personal information, please contact us here.

WHAT ABOUT WEBSITE SECURITY?

Security is very important to us. We also understand that security is important to you. We take reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

HOW TO CONTACT US

If you have questions or comments about this Privacy Statement, please contact us here.

STATE-SPECIFIC PRIVACY NOTICES

CALIFORNIA

Supplemental Privacy Notice for California Residents

This notice for California residents supplements the information contained in our Privacy Statement and applies solely to residents of the State of California “Supplemental Notice”. We adopt this Supplemental Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Supplemental Notice. Under the California Consumer Privacy Act (“CCPA”), you have certain rights in relation to some of your personal data, including the right to certain disclosures and explanations of rights. This section explains your rights under California law.

CALIFORNIA 'DO NOT TRACK' DISCLOSURES

California law (CalOPPA) requires us to let you know how we respond to web browser 'Do Not Track (DNT) signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not honor Do Not Track requests at this time.

CALIFORNIA CONSUMER PRIVACY ACT OF 2018

Categories of Personal Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“personal information”). We may have collected the following categories of personal information from consumers through our websites, apps, services, devices, or other services within the twelve (12) months preceding the effective date of this Privacy Statement:

Personal Information Category

  • Identifiers such as
    • Name
    • Address
    • Unique personal identifier (e.g., device ID, online identifier)
    • Internet Protocol address
    • Email address
    • Account name
    • Social security number
    • Driver’s license number, or
    • Other similar identifiers
  • Characteristics of protected classifications under California/federal law (e.g., age, race, sex, medical condition, etc.)
  • Medical information
  • Health insurance information
  • Financial information, including credit card numbers
  • Biometric information (e.g., imagery of the iris, retina, fingerprint, face, or other data that contain identifying information)
  • Commercial information (e.g., purchase history)
  • Internet or other electronic network activity information (e.g., browsing history, interaction with our website, etc.)
  • Geolocation data
  • Audio, electronic, visual, thermal, olfactory, or similar information (e.g., call recordings)
  • Professional, employment-related, or other similar information

“Personal information” under the California Consumer Privacy Act does not include information that is

  • publicly available from government records,
  • de-identified or aggregated consumer information,
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, or
  • certain personal or financial information covered under certain sector-specific privacy laws.

For additional information, please see How Do We Keep and Use Personal Information.

Categories of Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from consumers’ interactions with us, including with our devices, applications, websites, services, and representatives
  • Publicly available sources
  • Customers, including health care providers and insurance providers
  • Organizations with whom we partner to provide services to consumers
  • In connection with an acquisition or merger. Such information will be subject to this policy

Use or Disclosure of Personal Information

In the past 12 months, we have used or disclosed the personal information we collect for our operational purposes and for one or more of the following business purposes:

  • To provide products and services to consumers, such as facilitating the creation of a Klue user account
  • To respond to consumer requests
  • To improve and personalize consumer access to and experience on our website and mobile application, for example, by telling consumers about new features, products, or services that may be of interest to them
  • To develop records, including records of consumers’ personal information
  • To contact consumers with information that might be of interest to them, including information about clinical trials and about products and services of ours and of others
  • For analytical purposes and to research, develop, and improve programs, products, services and content
  • For activities to monitor and maintain the quality or safety of our products and services
  • For activities described to consumers when collecting their personal information or as otherwise permitted under CCPA
  • For U.S. healthcare providers, to link name, state license number, and/or IP address to web pages they visit, for compliance, marketing, and sales activities
  • To conduct audits and perform troubleshooting activities of our websites, products, and services
  • To detect and protect against security incidents and deceptive, malicious, or fraudulent activity
  • To ensure our website, products, apps, and services function as intended, including debugging and repairing
  • To comply with a law or regulation, court order or other legal process

Please see How Do We Keep and Use Personal Information in our Privacy Statement for more information.

How We Share Personal Information

We will not share consumers’ personal information with an unrelated third party without permission, except as described below. We may share personal information with any member of our corporate group, including parent companies, subsidiaries, and affiliates, and other companies in which we have an ownership or economic interest for purposes that are consistent with those identified in our Privacy Statement and this Supplemental Notice.

In the ordinary course of business, we will share some personal information with companies that we hire to perform services or functions on our behalf. In all cases in which we share consumers’ personal information with a third party, we will only allow them to keep, disclose, or use consumers’ information to provide the services we asked them to provide.

We may be required to release consumers’ personal information in response to a court order, subpoena, search warrant, law, or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior which is harmful to other users or illegal. In addition, we may keep, disclose, and use consumers’ personal information in order to comply with U.S. FDA and other governmental guidance, directions, regulations, and laws.

Categories of Personal Information We Sell

We do not sell personal information of California consumers.

This does not include disclosures that are not a “sale” under the CCPA, including when

  • consumers instruct us to disclose their personal information,
  • a consumer instructs us to interact with a third party that does not sell that information,
  • we use or share consumers’ personal information pursuant to a written contract with a service provider that is necessary to perform a business purpose, where our contract prevents the provider from using, keeping, or disclosing consumers’ personal information for any purpose other than the reason supplied in the contract, or
  • consumers’ personal information is transferred as part of a transaction in which the third party assumes control of all or part of our business.

Personal Information on Minors

We do not sell personal information of California consumers, including minors.

Rights under California Law

  1. Right to Access. If you are a California consumer, you have the right to ask us to send you the following information up to two times in a twelve-month period:
  • The categories of personal data we have collected about you.
  • The categories of sources from which we collected the personal data.
  • Our business or commercial purpose for collecting personal data.
  • The categories of third parties with whom we share personal data.
  • What categories of personal data we disclose about you for business purposes.
  • What categories of personal data we sell or exchange for consideration about you.
  • The specific pieces of personal information we have collected about you.
  1. Right to Delete. If you are a California consumer, you have the right to ask us to delete the personal data about you we have collected. You may change or delete your personal information on your profile at any time by logging onto your account and editing your profile information. We may deny the request if the information is necessary to:
  • complete a transaction, including providing a requested or reasonably anticipated good or service, or fulfill a contract between the consumer and Klue and/or Medtronic Diabetes;
  • detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take against those responsible for such activity;
  • debug to identify and repair errors impairing intended functionality;
  • exercise free speech or another right provided for by law;
  • comply with the California Electronic Communications Privacy Act;
  • engage in research in the public interest adhering to applicable ethics and privacy laws where the consumer has provided informed consent;
  • enable solely internal uses reasonably aligned with the consumer’s expectations based on the consumer’s relationship with us;
  • comply with a legal obligation; or
  • otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided the information.
  1. Right to Opt-out of the sale of personal information. If a business sells personal information to third parties, California consumers have the right, at any time, to opt out of the sale or disclosure of their personal information to third parties. We do not sell personal information to third parties.
  2. Right to designate an authorized agent. You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorize agent, please contact us here.
  3. Right to non-discrimination. The CCPA grants California consumers the right not to be discriminated against for exercising your privacy rights. If you exercise your privacy rights, we will not discriminate against you, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.

Submitting a Request or Inquiry

You may access, change, correct, or update any of your personal information in your Account by editing your profile within your account (if this feature is available to you. If you are a California resident and you want to submit a request or inquiry to us regarding your California rights, you or your authorized agent can contact us here or call us at 1‑866‑639‑6907 starting January 1, 2020. You do not have to create an account with us to submit a request.

Your request will be confirmed within ten days of receipt and we will respond within 45 days. If we need more than 45 days, we will notify you that your request is being delayed.

We can only respond to your request if it is verifiable. This means we are obligated to take reasonable steps to verify your identity or your authorized agent’s authority and your right to access the information you request. We may ask for additional information that will help us do so. We will only use that additional information in the verification process, and not for any other purpose.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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