Contour App Privacy Policy, REV 1.3
Table of Contents
Contents'
Contour Diabetes App Privacy Policy ........................................................................ 3
Introduction ................................................................................................................. 3
Using the Contour App ............................................................................................... 3
Creating a Contour Cloud Account .......................................................................... 3
Diabetes Management ................................................................................................. 3
Personal Data Submission and Collection ................................................................ 4
The Reasons For Processing Your Personal Data .................................................... 5
Marketing .................................................................................................................... 6
Sharing Your Personal Data ...................................................................................... 6
Using the Contour App to Send Reports ................................................................... 7
My Patterns ................................................................................................................. 7
Third Party App Connections .................................................................................... 7
Keeping Your Personal Data Secure ......................................................................... 8
Cookies and Similar Technologies ............................................................................. 8
Use of Cookies ......................................................................................................................................................... 8
How We Use These Technologies ........................................................................................................................... 9
Your Choices ........................................................................................................................................................... 9
Do Not Track ........................................................................................................................................................... 9
Data Storage ................................................................................................................ 9
Contour Cloud Account Deletion ............................................................................... 9
Exercising Your Rights ............................................................................................ 10
Children ..................................................................................................................... 11
Changes to this Privacy Policy .................................................................................. 11
Contact Us .................................................................................................................. 11
Contour Diabetes App Privacy Policy
Effective Date: February 2025, REV 1.3
Introduction
We know that you care about your personal data and how it is used, and we want you to trust that Ascensia uses your personal
data carefully. This Privacy Policy will help you understand what personal data we collect, why we collect it and what we do
with it. This Privacy Policy, together with the End User Licence Agreement (EULA), applies to your use of the Contour
Diabetes app.
The Contour Diabetes app is operated by Ascensia Diabetes Care Holdings AG (“Ascensia,” “we,” or “us”), based in Peter
Merian-Strasse 90, 4052 Basel, Switzerland. Ascensia is the controller of your personal data processed via the Contour
Diabetes app.
The Contour Diabetes app is a secure cloud-based diabetes management service that is a part of the Ascensia Diabetes Care
portfolio of diabetes management products and services. The Contour Diabetes app is compatible with the Ascensia portfolio
of blood glucose meters (Cable Connected Meter) and other Bluetooth (Wireless BLE Connected Meter) enabled devices or
other products designated to be compatible with the Contour Diabetes app.
Residents of the European Economic Area, United Kingdom, and Switzerland: Ascensia relies on the legal basis of
consent to process your health-related information for the purpose of providing you with the Contour Diabetes app and the
Contour Cloud Account. You may withdraw your consent at any time by using the “Delete Account” option in the Contour
App.
Please read this Privacy Policy before consenting to create a Contour Cloud account.
Using the Contour App
You must create a Contour Cloud account in order to use the Contour App. When creating your account, you will be asked to
select your country and language so that we can provide you with the correct version of this Privacy Policy and the EULA.
You will also be asked to accept the EULA terms and conditions before being able to use the Contour App.
Creating a Contour Cloud Account
Once you complete your registration for a Contour Cloud account, your personal data will be backed up to the cloud. You will
be able to access the data stored in your Contour Cloud account, including your blood glucose readings, on multiple devices.
Creating a Contour Cloud account will ensure that the Contour Connected Meter you pair with the Contour App can sync
information and settings, such as Target Ranges.
Upon creating a Contour Cloud account, you will be asked to consent to the processing of your health-related information as
described in this Privacy Policy. You can withdraw your consent at any time by deleting your account (see “Contour Cloud
Account Deletion” below). Please do not create a Contour Cloud account if you do not wish for your health-related information
to be processed by us.
Diabetes Management
The Contour App and Contour Cloud services are designed to help you manage your diabetes by automatically syncing and
logging your blood glucose results so you can understand how your activities impact upon them. The Contour App and
Contour Cloud account require Wi-Fi and/or data connectivity for syncing and retrieving your blood glucose results via your
smartphone. The Contour App and Contour Cloud services simplify the management of your diabetes but the services are not
a substitute for medical advice. Ascensia recommends that you seek regular advice from your health care provider regarding
your diabetes. Ascensia does not provide medical advice to users. We recommend that you contact your health care provider
or your local emergency services if you suspect you may have a medical emergency. The members of our customer support
team are not authorised to provide medical advice relating to the substance, meaning, or possible consequences of any blood
glucose results uploaded to the Contour App or Contour Cloud account.
Personal Data Submission and Collection
Ascensia will process your personal data when you submit it in the following ways:
•
Contour Cloud Account Registration and Profile Details: When you create a Contour Cloud account, the
following information will be stored: your name, gender, email address, date of birth, country, authentication details
and other registration information, including your chosen password for a Contour Cloud account. Where a user is
under the legal age of majority, we will request and collect the email address of a parent/guardian for verification
purposes. The Contour App can be used to capture information about your diabetes management, condition of
health and your Contour Connected Meter. This may include your diabetes type, medications, insulin, food
consumption and exercise regime, your hospital address and hospital attendance dates, health care practitioner
reports, blood glucose readings, A1c data, and meter model number, serial number and settings.
•
Access to Mobile Device System Services: Depending on your mobile device operating system, you may be asked
if you want to give access to certain system services on your device, such as camera, photos and contact list. Access
to these system services allows certain optional features of the Contour App to function properly, and does not result
in Ascensia having access to, collecting or storing any information relating to such system services. You can manage
the Contour App’s access to these system services in your mobile device/the Contour App’s settings.
•
Emergency Contact: You may choose to include emergency contact information of someone you would want
contacted in case of an emergency. The information about your emergency contact is only stored locally on your
smartphone and is not collected or stored by us in your Contour Cloud account.
•
Customer Services: If you contact us about the Contour App, your Contour Cloud account or for any other reason
relating to customer services, we will keep a record of that contact. You may provide us with personal data by
completing forms by e-mail as part of an order for products or services, where you have enquiries or requests or
when you report a problem with the Contour App and similar situations where you choose to give us your
information.
•
Device Information and Usage Details: When you use the Contour App, we will automatically receive technical
information, including the type of mobile device you use, a unique device identifier (such as UUID, a universal
unique identifier, or the mobile phone number used by the device), mobile network information, your mobile
operating system and software version number, IP address, the type of mobile browser you use, the country and
language code and time zone setting. Since users can log in from multiple devices, the UUID allows Ascensia to
synchronize data to enable end-to-end display of information in the app across all devices. If a user deletes the app,
the UUID is no longer usable. We will also collect information about your use of the Contour App, such as any
meter errors, log files and administration data so that we can ensure good operation of the Contour App.
•
Cookies and Similar Technologies: We may use cookies and similar technologies to collect information about
your interactions with certain services made accessible via the Contour App and other websites and applications.
See the “Cookies and Similar Technologies” section below to learn more about the technologies we use, why we
use them, and the choices you have.
•
Geo-Location Information: Where you agree to and have turned on location services during the registration
process for the Contour App, we will collect information about your precise or approximate location from
information derived from your mobile device. We ask for your consent to this collection during the App registration
process. You may withdraw your consent to our collection of your location information at any time by disabling the
use of location services in the device’s settings menu. Ascensia may also collect this information when you are not
using the Contour App if you have enabled the use of location settings through your device’s settings rather than
through the Contour App settings. We use this information to improve our products and services, including to
identify the distribution of Ascensia meters. If you are under the legal age of majority, we will seek the consent of
your parent/guardian for the collection of your location information, as further described in the “Children” section
below.
•
iOS Users: When you grant Ascensia access to Apple Inc.’s (“Apple”) Health app on your device, including
access to Apple’s Health app database, “HealthKit”, we will share your personal information and health data for
the purposes of enhancing and/or verifying the data processed within the Contour App. The amount of personal
information and health data that is shared will vary depending on your specific selections. Ascensia will not use or
disclose to third parties user data gathered from HealthKit for advertising or other use-based data mining purposes
other than improving health. See the “Third Party App Connections” section below for further details.
•
Artificial Intelligence: As part of providing our services to you, and where appropriate, we may use artificial
intelligence such as machine learning for automated analysis, for example to support Customer Services in
providing responses more quickly.
The Reasons For Processing Your Personal Data
We process your personal data, including health-related information, in the following ways:
•
with your consent to provide you with the Contour App and its services, functionalities, and to notify you of any
changes
•
to permit you to send reports of your blood sugar, as described in “Using the Contour App to Send Reports”
section below
•
to connect to other apps, where available, as described in the “Third Party App Connections” section below
•
to understand the locations where the Contour App and our meters are used to help improve our products and
services, including in connection with our meter placement strategy
•
to present information to you about your blood glucose testing and measurements to help you understand
patterns and trends relating to your diabetes so that you may better manage your diabetes, the “My Patterns”
notifications and related functions and settings
•
to allow you to participate in interactive features of the Contour App, when you choose to do so
•
to provide you with cloud services if you choose to set up a Contour Cloud account
•
to respond to any request we may receive from you, such as requests for Contour App or Contour Cloud
account support
•
if you are a parent or guardian, to enable you to create a Contour Cloud account for use by your child, and to
allow you to manage their use of the Contour Cloud account.
•
for purposes related to public health related to medical devices, to conduct research and for our legitimate business
interests including for statistical purposes to
•
continue to develop, test and improve the Contour App and Contour Cloud services, including to offer new
functionality and features
•
better understand how you interact with the Contour App, including its functionality and features, as well as
ensure that content is presented in the most effective manner
•
help us fix any issues with the Contour App or Contour Cloud services, including where we respond to your
questions or respond to your request for support, maintenance, troubleshooting, or other performance issues
•
conduct data analysis, testing and research, including for statistical purposes
•
develop and implement security tools and mechanisms as part of our efforts to keep the Contour App safe and
secure
•
issue a safety notice or corrective action related to the Contour App, our meters or your Contour Cloud account
whenever necessary.
•
for our legitimate business purposes relating to direct marketing, and where required, consent to:
•
invite you to participate in surveys or opinion groups or other promotional and marketing activities related to
the operation and your use of the Contour App, the Contour Cloud account or concerning our products and
services, including in conjunction with selected third parties
•
measure and understand the effectiveness of advertising we may serve and to deliver relevant advertising
•
make suggestions and recommendations about products or services that may interest you, including to receive
such information from your local Ascensia company, as described in the “Marketing” section below.
•
Where required by law, including legal requirements relating to the safety of medical devices.
For reasons of public interest in the area of public health relating to medical devices, to conduct scientific research and/or for
our legitimate business purposes, Ascensia may use, analyse and disclose statistical, aggregated, anonymised or de-
identified/pseudonymised information (this is information with which Ascensia will not identify you individually and cannot
reasonably be used to identify you) to: our local Ascensia affiliates, third party researchers or to governmental or regulatory
authorities with oversight for medical devices and/or national authorities with responsibility for medical reimbursement and
funding. We do this for the purposes of:
•
determining and improving the effectiveness of diabetes management techniques, therapies, treatments and costs;
•
researching and evaluating how the Contour App and the Contour Cloud account services are provided and used
including in relation to marketing strategies;
•
evaluating the performance, impact and experience of the Contour App and Contour Cloud account on users
(including based on user demographics, such as geography);
•
evaluating the performance and interface of the Contour App with blood glucose meters;
•
enhancing the functionality and features of the Contour App and the Contour Cloud account services;
•
testing and validating Contour App upgrades and improvement, including in relation to our medical devices, such
as our diabetes meters and test strips;
•
Ascensia’s operating and business strategy for research and development, distribution and business efficiencies
and operations; and
•
scientific research, statistical purposes and analysis, relating to diabetes, including publishing articles in medical
and/or peer-reviewed publications and journals.
For reasons of public interest in the area of public health relating to medical devices and/or for our legitimate business
purposes, Ascensia may also collect and use technical information about your smartphone, mobile devices and related
software, hardware and peripherals that are internet-based or wireless to improve our products and services and to provide
with you the various functionalities of the Contour App.
YOU AGREE THAT, BY CREATING A CONTOUR CLOUD ACCOUNT, YOU CONSENT TO THE
PROCESSING OF YOUR SENSITIVE HEALTH-RELATED INFORMATION, AS DESCRIBED IN THIS POLICY.
Marketing
We may contact you to tell you about products and services that we feel may be of interest to you or that are similar to those
that you have already purchased or enquired about. You may also be contacted by your local Ascensia company, a distributor
of Ascensia products, or one of our selected partners, in each case, where you have consented to receive these
communications.
You may opt out of receiving our marketing communications at any time by contacting customer service by visiting
http://contact.ascensia.com or by using the unsubscribe link in any of our communications.
We will continue to contact you for non-marketing related purposes where we need to send you information about the Contour
App, your Contour Cloud account or where we need to issue a field corrective or safety notice. We may send information to
you via Contour App notifications, reminders or alerts to inform you of new developments. You can manage push notifications
in your mobile device settings.
Sharing Your Personal Data
We do not rent or sell your personal data to anyone. Ascensia may share your information with:
•
third parties you direct us to share your information with;
•
your local Ascensia company and Ascensia Diabetes Care US Inc. for purposes consistent with this Privacy
Policy. The details of your local Ascensia company are listed on our website at http://diabetes.ascensia.com/en/
contact-us;
•
our service providers involved in the development, provision, troubleshooting or fixes relating to support, testing
and maintenance of the Contour App, Contour Cloud services or the related services offered through the Contour
App who process information for us, based on our instructions, and in compliance with this Privacy Policy and
any other appropriate confidentiality and security measures;
•
distributors of our products, if you live in a country where we use a distributor;
•
our selected partners where you have chosen to participate in surveys, contests, opinion groups or other
marketing-related initiatives relating to your use of our products and services. The third parties will use the
information we provide to them, along with any information you provide during your entry, request, or
participation, in order to (i) notify you if you have won a prize in a contest or sweepstakes, and (ii) to fulfil, or
facilitate fulfilment of, requests for products or services you may make in connection with your entry, request, or
participation. These third parties are contractually obligated to keep all such information confidential and to only
use it for the purposes for which it was provided; or
•
a prospective seller or buyer in the event of a sale or purchase of any Ascensia business or asset so that the buyer
can continue to provide you with information and services.
We may share your personal data with our distributors, business partners, or service providers, including for marketing
purposes or where you have chosen to share your personal data through various features and functionality provided via the
Contour App. In each case, we will only share your personal data with third parties so that we may provide, maintain, host
and support the Contour App and Contour Cloud accounts.
We may disclose your personal data where required to respond to authorized requests from government authorities or where
required by law, including for national security. Where we are required by law, we may also disclose your personal data
where it is necessary to enforce or apply our EULA, this Privacy Policy or other agreements, to investigate or protect the
rights, property or safety of Ascensia and our group companies, our products and services and our customers, distributors or
business partners or to prevent or take action regarding illegal activities or fraud, situations involving potential threats to the
safety of any person or as evidence in litigation. Your personal data may be subject to foreign laws and may be accessible by
foreign governments, courts, law enforcement and regulatory agencies.
Using the Contour App to Send Reports
The Contour App may allow you to create a blood sugar report based on the information stored in your Contour Cloud
account. You may use the Contour App’s functions to send a report by email to third parties such as a doctor, medical provider
or other person of your choice. If you do choose to share your personal data with anybody, please do take care and make sure
your personal data is only shared with intended people.
Please note that any sharing of your personal data is wholly at your own risk and Ascensia is not responsible for securing or
protecting the information that you choose to send to other persons via the Contour App. You should be aware that there are
risks involved in sharing information over the internet, including the potential for such information to be intercepted by
unauthorised third parties. We recommend that you exercise caution when choosing to share your personal data.
My Patterns
The Contour App may allow you to receive information about various blood glucose patterns and statistics to help you better
manage your diabetes. These patterns relate to high and/or low levels of blood sugar, based on times of day, meal markers or
days of the week. The “My Patterns” functionality will detect your blood glucose testing patterns and may suggest changes to
improve testing times or frequency.
By using this function, you can set up reminders in the Contour App about when to test or retest your blood sugar levels or
follow links to helpful information so that you may better manage your diabetes.
Third Party App Connections
The Contour App may allow you to create a connection with mobile applications offered by third parties (“Third Party App”).
If you choose to connect with a Third Party App, you will be asked to consent to the sharing of the personal information
stored in your Cloud Account, which may include health-related information. Your personal information will only be shared
with a Third Party App when you direct us to make the connection. The amount of personal information that is shared with
the third party may vary depending on the Third Party App and your specific selections, and may include your blood glucose
reading value, measurement date and time, target blood glucose ranges by meal marker, your meal markers and meal type,
your activities, your medication and whether your reading was taken via your meter or manually.
You can find the list of Third Party Apps which are available for you to voluntarily connect to under Settings “App
Connections”. The App Connections function lists any Third Party Apps you have chosen to connect with and list Third Party
Apps that you may choose to connect to. You can revoke your consent to share your personal information with any Third Party
App at any time by clicking on the icon for the connected Third Party App icon and choosing to disconnect.
Please note that if you choose to create a connection with a Third Party App, the personal information that you share will be
processed in accordance with, and governed by, the third party’s privacy policy and terms and conditions.
Ascensia does not accept any responsibility or liability for these policies. Please check these policies before you connect with
any Third Party App.
Storing and Transferring Your Personal Data
Your personal data in your Contour Cloud account will be stored and processed on servers located in one of our regional
facilities which may include data hosted with one of our service providers. If you are a resident of a country with data
localization laws, your personal data will be stored on servers located within your country with our cloud service provider
who is our data processor for the hosting of Contour Cloud accounts. We otherwise endeavour to store your personal data
within the region where you reside. This means, for example, that data of European users is stored in France, and that data of
US users is stored in the US. There are limited circumstances where your data may move outside those regional facilities:
•
Where we produce statistics from user data for reports, using tools provided by partners, for example in the US.
Individuals cannot be identified from these reports.
•
To develop the Contour App, and to administer and provide you with support and technical services for your
Contour Cloud account.
Since we operate around the world, some of our colleagues, and the partners we work with, will be outside the country where
you live (or in which we provide the services), for example in India. If a data protection authority does not consider a country
to have adequate levels of protection for personal data, we will implement appropriate safeguards, to protect your personal
data if it is transferred. In most cases, the measures will include appropriate data transfer agreements with recipients of the
information (such as Standard Contractual Clauses, and the equivalent contracts in the UK, Switzerland, China and
elsewhere).
Keeping Your Personal Data Secure
Ascensia implements appropriate administrative, technical and physical safeguards to protect the confidentiality, integrity
and availability of your personal data. We will use strict procedures and security features, including cryptographic techniques,
and take all steps reasonably necessary to ensure your personal data is processed securely and in accordance with this Privacy
Policy.
You are responsible for protecting against unauthorised access to the Contour Diabetes app and your Contour Cloud account.
Ascensia recommends that you use strong password security, by using a mix of letters, numbers and symbols, and a different
password for your Contour Cloud account than you use for any other accounts that you may have. You must keep your account
information password confidential and not share it with anyone. Ascensia is not responsible for any lost, stolen or
compromised passwords or for any access to your Contour Cloud account from unauthorised users where caused by you. If
you think your account has been compromised, please contact us as soon as possible. For Customer Service please visit
http://contact.ascensia.com
Please note that the transmission of information via the internet is not completely secure. Although Ascensia will do its best
to protect your personal data, we cannot guarantee the security of your information transmitted to the Contour App and any
transmission is at your own risk.
Cookies and Similar Technologies
We may use information collection and tracking technologies for certain services and features made accessible to you via the
Contour Diabetes app to remember things about you so that we can provide you with a better experience.
Below we provide information on the technologies we may use for automatic information collection, why we use them, and
your choices.
Use of Cookies
Cookies are small data files stored on your browser or device. They are designed to remember things that a user has done while
on a website in the past, which can include logging in or clicking on links.
Cookies may be set by the entity that operates the website you are visiting (“first-party cookies”) or by other companies
(“third-party cookies”). Where applicable, we use the following cookies to collect information about your interactions with
certain services and other websites and Apps:
•
Strictly necessary cookies: Required for the operation of certain websites made accessible via the
Contour Diabetes app. They include, for example, cookies that enable you to log into secure areas of the web- based
App, to move around the website and to use its features.
•
Analytical/performance cookies: Allows Ascensia to recognise and count the number of visitors and to see how
visitors move around certain web pages made accessible via the Contour Diabetes app. This helps us to improve
the way such websites work, for example, by ensuring that users are finding what they are looking for easily.
•
Functionality cookies: These cookies recognize you when you return to our web-based App. This enables us to
personalise our content for you.
Some of these are persistent cookies that may be used if you log on to restricted areas to remember who you are. Others are
session cookies that may be used for anonymous identification of a website visit for technical purposes only. Session cookies
are stored only temporarily during the browsing sessions and are deleted once the browser is closed.
How We Use These Technologies
We use cookies and similar technologies for the following purposes:
•
Where required, to log you into the services we provide; enable us to show your account data; remember your
settings and preferences, for example, your choice of language or region; and to help us personalise your
experience and keep your data and the services we provide safe and secure.
•
To collect anonymous statistical information on how visitors use our services so that we can make improvements
to its usability and to improve content delivery value.
•
We use what is known as the Microsoft Azure SDK to understand:
•
Number of times users visit particular screen; and
•
Number of times users click on items on a particular screen.
This analytics cannot be tracked back to a specific user, but rather it allows us to improve the Contour Diabetes
app for all users, for example by changing screens that cause a large number of users to pause in the journey,
which might suggest confusion with language or design of the App.
•
We may also use Google Firebase Analytics to send messages, such as to notify you about changes to the Contour
Diabetes app.
Your Choices
•
Although most browsers are set-up to accept cookies automatically, it may be possible to refuse to accept browser
and device cookies by activating the appropriate setting on your browser or device. Please note that if you choose
not to permit cookies some features of our services may not function properly or be accessible.
•
To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.
•
You may use self-regulation programs available in your jurisdiction to manage the way that companies other than
Google advertise to you, such as the EU-based Your Online Choices.
Do Not Track
Ascensia does not collect personal data about your online activities over time and across third-party websites or online
services. We also do not allow third parties to collect personal data about your online activities over time and across other
websites or online services when you use the Contour Diabetes app. We do not respond to browser “Do Not Track” signals.
Data Storage
Ascensia will continue to store your personal data while you have an active Contour Cloud account. The section on “Contour
Cloud Account Deletion”, below, explains how you can delete your Contour Cloud account and what happens to your personal
data once your account has been deleted.
Contour Cloud Account Deletion
If you would like to delete your Contour Cloud account, you may do so by using the “Delete Account” option in the Contour
App or contacting us. For Customer Service please visit http://contact.ascensia.com Please be aware that if you delete your
account we will retain aggregated and de-identified information and we may need to retain certain personal data as required
by law.. We retain data in your Contour Cloud account for two years from the date it is uploaded to enable you to access and
export such data, if required, in connection with an insurance claim..
Once your Contour Cloud account and any associated personal data has been deleted, you will no longer have access to the
account and deletion of your account may be irreversible. You may not therefore be able to reactivate your Contour Cloud
account or retrieve any personal data, including health related information. You may want to download and save any required
information before deleting your account or requesting that we delete your account.
If you have chosen to share your Contour Cloud account information with a third party such as your healthcare provider or
other person and you delete your account, those persons will no longer be able to view your account information, including
information about your blood glucose readings.
Ascensia reserves the right to delete Contour Cloud accounts that remain inactive for an extended period of time. Where a
Contour Cloud account remains inactive, we will notify you in advance so that you have an opportunity to ensure your account
stays current and available for your use.
Exercising Your Rights
If you need to update your information you can do this through the Contour App. If you are unable to access that information
for any reason, you can notify Ascensia of any changes to (or errors in) your information and we will update it for you by
submitting a written request for changes using the contact information provided below.
Residents of the European Economic Area (EEA) or Switzerland: You may have the right to: (a) access the personal data we
hold about you; (b) request we correct any inaccurate personal data we hold about you; (c) request we delete any personal
data we hold about you; (d) restrict the processing of personal data we hold about you; (e) object to the processing of personal
data we hold about you; and/or (f) receive any personal data we hold about you in a structured and commonly used machine-
readable format or have such personal information transmitted to another company.
Residents of the People’s Republic of China, Taiwan, Hong Kong, Indonesia, South Korea, Malaysia and Argentina: You may
have the right to: (a) access the personal data we hold about you; (b) request we correct any inaccurate personal data we hold
about you; (c) request we delete any personal data we hold about you; and/or (d) restrict the processing of personal data we
hold about you.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information
requested to you.
Where you have been asked to consent to the processing of your personal data, we will provide you with an opportunity to
withdraw your consent. You can withdraw consent, such as by contacting us using our contact details below. In each case you
will be given information about how to withdraw consent. Any withdrawal of consent will not affect the lawfulness of the
processing based on your consent before the withdrawal. Please also note that where you withdraw consent, we will only stop
processing your personal data that relates to the withdrawal of consent.
To exercise any of your rights in connection with your personal data, please contact Ascensia by email at
dp_office@phchd.com or by mail to Ascensia Diabetes Care Holdings AG, Peter Merian-Strasse 90, 4052 Basel, Switzerland.
We will process any request in line with any local laws and our policies and procedures. If you are located in the EEA, you
have the right to lodge a complaint about how we process your personal data with the supervisory authority in your country.
California Privacy Rights:
Our California Privacy Disclosure explains how we collect, use and disclose the personal information of California residents
subject to the California Consumer Privacy Act, amended by the California Privacy Rights Act (“California Privacy Rights
Act”). This Disclosure also applies to residents of other US States with similar privacy laws, as applicable.
If you are a resident of California or specific other US States, with certain legal exceptions and limitations, you may exercise
the following rights via our webform located on our website or by calling (800) 348-8100. If you would like to know if the
rights apply to you, please contact: dp_office@phchd.com. If submitting a request via our webform, please indicate which
right your request relates to in the “Message” section.
You may be required to verify your identity when you contact us to make a request to know or delete your personal data. We
must verify your identity to ensure that you are the person about whom we may have collected personal data or a person who
has been duly authorized to make the request on behalf of such person. If you are required to verify your identity, we may ask
you to provide evidence that matches information maintained by Ascensia such as verifying name, email address, mailing
address, telephone number and/or credit card information if maintained in our records.
You may use an authorized agent to exercise your rights on your behalf. You must provide your authorized agent with written
permission to exercise your rights on your behalf and we must be able to verify your identity as described above. If you are
an authorized agent, you must contact us at (800) 348-8100.
Right to Know. You have the right to request information about the categories and specific personal data we have collected
about you, the sources of personal data, the purposes for collecting the personal data, the categories of third parties to whom
we have shared personal data, and the purposes for which it was shared. If you need to export your information from the
Contour App, you can do this through the App under the "My Care" section. If you would like to request additional
information, please contact us as described above.
Right to Delete. You have the right to request that we delete your personal data.
Opt Out of Sale. We do not sell your personal data to third parties.
We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.
Parents/Guardians: If you are the parent or guardian of a child that uses our services, please see the "Children" section below
to understand and exercise your rights.
Children
We will not collect or use the personal data of anyone we know to be under the legal age of majority without the prior
affirmative, verifiable consent of his or her parent/guardian. We employ reasonable technological safeguards to prevent
children from registering to use the Contour App where personal data may be collected. We collect only as much information
from children as is reasonably necessary to use the Contour App and to create and use a Contour Cloud account. At the point
of registration, where a user’s date of birth indicates that they are under the legal age of majority we will ask for the contact
email address of their parent/guardian. The parent/guardian will be sent an email requesting that they visit a web page to
approve the creation of a Contour Cloud account and click to accept this Privacy Policy. A Contour Cloud account can only
be registered once the parent/guardian has taken these steps. A parent/guardian has the right, upon request, to view the
information provided by their child and/or to require that it be deleted. If you are a parent/guardian with any concerns regarding
your child’s personal data in connection with the Contour App, please contact Ascensia at dp_office@phchd.com or by mail
to Ascensia Diabetes Care Holdings AG, Peter Merian-Strasse 90, 4052 Basel, Switzerland.
If you are located in the United States and have questions about Ascensia and the Children’s Online Privacy Protection Act,
you may also contact our U.S.-based subsidiary directly at Ascensia Diabetes Care US Inc., 5 Wood Hollow Rd, Parsippany,
NJ 07054 USA or via telephone at +1 (862) 225-2902. Please be aware that if you contact our US subsidiary, we will keep a
separate record of that contact.
Changes to this Privacy Policy
Any changes to this Privacy Policy in the future will be posted on this page and, at our discretion, provided to you by e-mail
or via a push notification on the Contour App.
Contact Us
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to the Data Protection
Officer at dp_office@phchd.com or to Ascensia Diabetes Care Holdings AG, Peter Merian-Strasse 90, 4052 Basel,
Switzerland. If you contact us, we will do our utmost to address any concerns you may have about our processing of your
personal data.
