EDDII.INC

Privacy Policy

 

Last modified: March 17th, 2021

 

By using our mobile application (the “App”) or by accessing www.eddihealth.com and any affiliate sites including social media outlets (collectively, our “Site”) or by submitting any personal information, you are accepting the terms of this Privacy Policy. 

 

This Privacy Policy describes how we look after your personal information when you visit our Site or use our App and the types of information we may collect form you or that you may provide when you use our App or visit our Site and our practices for collecting, using, maintaining, protecting, processing and disclosing that information. 

 

This Privacy Policy is provided in layered format so you can click through to the specific areas set out below.

 

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, DO NOT USE ANY OF THE SERVICES OR THE APP.

 

1. Purpose of this Privacy Policy and More on Eddii.

 

Eddii.inc (“Eddii”, "Company" or "We") respects your privacy and is committed to protecting it through our compliance with this policy.  Eddii’s Services helps you track information including your continuous glucose levels through third-party devices that measure continuous glucose (“CGMs”) or other glucose measuring devices (collectively, “Connected Devices”), physical activities, weight and sleep to support your management of what you eat, your medications, feelings, blood glucose levels and overall lifestyle choices (collectively, the “Services”).  The Services educate you on certain health patterns, engage you with games and rewards and provide support to help you better manage your nutrition and mental health.  Our Services are offered to adults, parents and their children who have registered for an account with Eddii (an “Account”).  A person with an Account or a visitor to our Site or App is referred to as “you” or a “user”.

 

This policy describes the types of information we may collect from you or that you may provide when you use our App or visit our Site and our practices for collecting, using, maintaining, protecting, and disclosing that information.

 

This policy applies to information we collect:

  • Through the App or on the Site.

  • In email, text, and other electronic messages between you and the App or the Site.

  • Through mobile and desktop applications you download from the Site, which provide dedicated non-browser-based interaction between you and the Site.

  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

  • When you use our App as defined in the Terms of Use available at www.eddiihealth.com/terms-of-use (the “Terms”).

 

It does not apply to information collected by:

  • us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

  • any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.

 

Terms not otherwise defined herein have the meaning set forth in the Company’s Terms of Use found at www.eddiihealth.com/terms-of-use 

 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site or our App. By accessing or using this App or this Site, you agree to this privacy policy. This policy may change from time to time (see Changes to our Policy). Your continued use of the App or the Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

 

2. Authorized Users of the Site

 

This App and the Site are offered and available to users subject to the Company’s Terms of Use, www.eddiihealth.com/terms-of-use, who are 18 years of age or older, and reside in the United States or any of its territories or possessions; or youth over the age of 13 who have received permission from a parent or legal guardian.  If you are under the age of 18, you must ask your parent or guardian for permission to use this Site.  If you are under 13, you must ask your parent or legal guardian create an Account and ask your parent or legal guardian to create a sub-account for you.

 

Children’s COPPA Privacy Notice.  We do not knowingly collect personally identifiable information from children under the age of thirteen.  The first page of our intake form for prospective new subscribers is a request for a first name and age.  If a prospective new subscriber lists his or her age as under 13, then we will direct that prospective new subscriber to ask his or her parent or legal guardian to subscribe and to create a sub-account for the child under 13.  If you believe we might have any information from or about a child under 13, please contact us at support@eddiihealth.com  For further detail regarding our interactions with children under 13, please see our COPPA Privacy Notice available here

 

3. Information We Collect About You and How We Collect It

 

We may collect several types of information from and about users of our Site and App and you may provide us with certain information at your discretion, which may include information:

  • by which you may be personally identified, such as name, postal address, e-mail address, age, gender, your use of the App or the Site, telephone number, username, and any other identifier by which you may be contacted online or offline ("personal information");

  • that is about you but individually does not identify you including type of diabetes, medication delivery method, meal times, target blood glucose range; and/or

  • about your internet connection, the equipment you use to access our Site or our App and usage details.

 

We collect this information:

  • Directly from you when you provide it to us including through your use of our App and the Site.

  • Automatically as you navigate through the Site or the App. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

  • From third parties, for example, our business partners.  For example, we use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding your use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

We do not require you to provide any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

 

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal identifiable information. Unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure.  As a result, while we strive to protect your personal information, you acknowledge that (a) there are security and privacy limitations inherent to the internet which are beyond our control; and (b) security, integrity and privacy of any and all information and data exchanged between you and us through this Site or through the App cannot be guaranteed. 

 

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through a public message board, this information may be collected and used by others.

 

4. Information You Provide to Us

 

The information we collect on or through our Site may include:

  • Information that you provide by filling in forms on our Site or by the App. This includes information provided at the time of registering to use certain areas of our Site and information provided at the time of subscribing to or registering for use of our App, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Site or our App.

  • Records and copies of your correspondence (including email addresses), if you contact us.

  • Your responses to surveys that we might ask you to complete for research purposes.

  • Details of transactions you carry out through our Site or use of our App.

  • Your search queries on the Site or through the use of the App.

 

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. Your User Contributions may be accessible by the general public and are being disclosed at your own risk.

 

5. Information We Collect Through Automatic Data Collection Technologies 

 

As you navigate through and interact with our Site or our App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Site or use of our App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.

  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

 

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

 

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

 

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize our Site and App according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to our Site or App.

 

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or your smartphone. You may refuse to accept browser cookies by activating the appropriate setting on your browser and it may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain Services.

  • Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site and use of our App. Flash cookies are not managed by the same browser settings as are used for browser cookies.

  • Web Beacons. Pages of our Site, portions of our App, and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

  • Geolocation.  The App may collect real-time information about the location of your device and such information may be used by third-parties with whom we contract to provide certain information to you available through the App.

 

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.  Please see additional information on our Cookie Policy. 

 

6. Third-Party Use of Cookies and Other Tracking Technologies

 

When you use the Site or the App or the respective content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Advertisers, ad networks, and ad servers.

  • Analytics companies.

  • Your mobile device manufacturer.

  • Your mobile service provider.

  • Your internet provider.

  • Data aggregators.

  • Sources of information available to you through the App or through the Site.

These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site or our App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

 

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising form many providers, see Section 9 below.

 

7. How We Use Your Information

 

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Site and the App and their respective content to you including access to and use of the App.

  • To provide the Services.

  • To provide you with information, products, or services that you request from us.

  • To fulfill any other purpose for which you provide it.

  • To provide you with notices about your Account if applicable, including expiration and renewal notices.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • To notify you about changes to our Site or our App or any products or services we offer or provide though either the Site or the App.

  • To allow you to participate in interactive features on our Site and through our App.

  • In any other way we may describe when you provide the information.

  • To provide technical, product and other support to you.

  • To evaluate and improve our Site and the App and to develop new products and services.

  • To improve our advertising and/or promotional campaigns.

  • For any other purpose with your consent.

 

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your Account profile if applicable.

 

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

 

We may use location information we collect to provide you with certain features of the App. The features, information and assessments available to you through the App may change at any time.  We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you.  If you do not want us to use your information in this way, please adjust your user preferences in your Account profile (See Section 9 below) or contact us at support@eddiihealth.com.

 

8. Disclosure of Your Information

 

Do not submit your information if you do not want it collected, used and disclosed.

 

We may disclose Aggregated Date about our users, and information that does not identify any individual, without restriction.

 

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.

  • To our contractors, service providers, and other third parties we use to support or further our business (including for example Google Analytics) and others who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Site users is among the assets transferred.

  • To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. To fulfill the purpose for which you provide it.

  • For any other purpose disclosed by us when you provide the information.

  • With your consent.

  • To comply with any court order, law, or legal process including to respond to any government or regulatory request.

  • To enforce our rights arising from any contracts entered into between you and us, including our Terms of Use and for billing and collection.

  • If we believe disclosure is necessary or appropriate to protect the rights, property or safety of Eddii, our users or others.  This includes exchanging information with other companies and organizations for purposes of fraud protection and risk reduction.

 

9. Choices About How We Use and Disclose Your Information

 

Do not submit your information to us if you do not want it collected, used and disclosed.

 

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this Site or the App may then be inaccessible or not function properly. You can choose whether or not to allow the App to collect information through other tracking technologies by contacting us at support@eddiihealth.com and requesting to opt-out. 

  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, do not submit your information.

  • Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly

  • Promotion by the Company. If you do not wish to have your email address and/or contact information used by the Company to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or any other opt-out method we provide to you or at any other time by logging into the Site and adjusting your user preferences in your Account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to support@eddiihealth.com  If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by [OPT-OUT METHOD].

  • Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by logging into the App or the Site and adjusting your user preferences in your Account profile by checking or unchecking the relevant boxes or by sending us an email regarding the App or the Site stating your request to opt-out to support@eddiihealth.com

 

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

 

California residents may have additional personal information rights and choices. Please see the section below on Your California Privacy Rights for more information.

 

10. Accessing and Correcting Your Information

 

You can review and change your personal information by accessing your Account and visiting your Account profile page.

 

You may also send us an email at support@eddiihealth.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user Account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

 

If you delete your User Contributions from the Site or the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site or on the App, including User Contributions, is governed by our Terms of Use found at www.eddiihealth.com/terms-of-use

 

California residents may have additional personal information rights and choices. Please see section on Your California Privacy Rights below for more information.

 

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit: https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?division=3.&part=4.&lawCode=CIV&title=1.81.5

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@eddiihealth.com or write us at: Eddii Inc, 153 West 27th Street, Suite 700, New York, NY, US 10001.

 

11. Data Security

 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted.

 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site or the App like message boards. The information you share in public areas may be viewed by any user of the Site or the App.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or through the App.

 

We may retain and use your data as necessary to comply with our legal obligations, or resolve disputes. We will try to delete your data within the time limits imposed by applicable law, if any or upon request. If we have no justifiable business need to process your data, we will either delete or anonymize it, or, if this is not possible, for example, in case your data has been stored in backup archives, then we will securely store your data and isolate it from any further processing until deletion is possible.

Retention requirements can vary for different purposes, so we generally apply the retention periods as follows:  We retain any information collected via cookies, such as behavior data, including but not limited to clear gifs, flash cookies, webpage counters and other technical or analytics tools up to one year from expiry of the cookie or the date of collection. Your Data used for marketing purposes is stored indefinitely until you unsubscribe. Once you are unsubscribed from marketing communications, we add your contact information to our suppression list to ensure we respect your unsubscribe request. As required by applicable law, we will inform you that a call will be recorded if it is, and any telephone calls with you may be kept for a period of up to six years.

 

12. Changes to Our Privacy Policy

 

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated.

 

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this privacy policy to check for any changes.

 

13. Opting Out and Opting In

 

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, App subscription, warranty registration, product/service experience or other transactions.

 

Opt-in

If you sign up to receive promotional information, marketing offers, or announcements from us, the emails that you will receive will include the capability to opt-out through a link. Transactional and billing communications are not considered “marketing” or “informational” communications.

 

14. Contact Information

 

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

 

support@eddiihealth.com