Privacy Policy

Glucomodicum (also referred to as “we”, “us”, or “our”) is committed to protecting your privacy and complying with applicable data protection and privacy laws. This Privacy Policy (“Policy”) is designed to help you to understand what kind of information we collect in connection with our products and services and how we process and use such information. Throughout this Policy the term “personal data” means information relating to an identified or identifiable individual (i.e. a natural person). You acknowledge and agree that your personal data collected may be used in accordance with this Policy by and for one or more Glucomodicum group companies, which will be regarded, individually or jointly, as data controllers in respect of such data. Where a consent from you to the processing of personal data described in this Policy is required under the applicable law, such consent will be obtained by appropriate mechanism such as ticking a box stating your consent, choosing technical settings for a service or website, or other statement or conduct clearly indicating your acceptance to the processing, depending on the product, website, service or application you are using.

DATA COLLECTED

We collect your personal data typically when you interact with us. Below are examples of the categories of the data:

Technical Information. For the most part, you may visit our websites or use our products or services without having to identify yourself. However, certain technical information is normally collected as a standard part of your use of our services. Such information includes, for example, your IP-address, access times, the website you linked from, pages you visit, the links you use, the ad banners and other content you viewed, information about your devices and other such technical information your browser provides us with or as may be otherwise collected in connection with certain products and services. When you use our services or otherwise interact with us over telecommunications networks, certain additional information, such as your mobile subscription number, may be transmitted to us by the telecommunications operator as a standard part of that communication. Please also see the section “Use of Cookies and Web Beacons” below.

Information you provide us. We may also collect other information you provide, such as your consents, preferences and feedback, information you provide us with. Please note that certain non-identifiable information collected from you may become personally identifiable when you provide us with your personal data. Some of our services may allow you to submit information about other people, for example, if you make an order for a product that you wish us to send directly to another recipient.

Mandatory personal data, the provision of which is necessary, for example, for the performance of contractual or legal obligations and for the performance of clinical studies and the provision of other services or the organization of events and recruitment consist of name, email, phone number and potentially your address.

THE PURPOSES OF PROCESSING AND LEGAL BASIS

Glucomodicum processes your personal data for the purposes described in this Policy and/or any additional service specific privacy information. Please note that one or more purposes may apply simultaneously.

Provision of products and services. We may process and use your personal data to provide you the product or service you have requested, fulfill your other requests such as customer service, process your order or as otherwise may be necessary to perform or enforce the contract between you and Glucomodicum. We may also process and use your personal data to ensure the functionality and security of our products and services, to identify you, and to prevent and detect fraud and other misuses.

Development of products and services. We may process and use your personal data to develop our products and/or services. However, for the most part we only use aggregate and statistical information in the development of our products and services, and not data directly identifiable to you. We may also process and use your personal data to personalize our offerings and to provide you with service more relevant to you, for example, to make recommendations and to display customized content and advertising.

Communicating with you and marketing. We may process and use your personal data to communicate with you. We may process and use your personal data for marketing. Marketing purposes may include using your personal data for personalized marketing or research purposes in accordance with applicable laws, for example, to conduct market research and to communicate our products, services or promotions to you via our own or third parties’ electronic or other services. In addition, some of our products and services may be used to promote products and services of other companies. However, Glucomodicum does not disclose your personal data to such companies for their marketing purposes without your prior consent.

The legal bases applicable to the processing are: agreement, legal obligation, legitimate interest of the controller and consent.

In case of clinical study and usability study volunteers, candidates, employees or visitors of our webpages the legal basis for processing of personal data is consent. Consent as a basis for the processing of personal data described in this data protection statement is obtained using an appropriate method, such as ticking a box indicating your consent, making a choice in the technical settings of the service or website or another clear statement or action indicating your consent, depending on the website or service you use or your role in our studies. In principle, such consent is always as easily revocable as it has been given. See below for a mechanism for withdrawing your consent.

If the processing of personal data for clinical study or usability study volunteers cannot be based on consent (for example due to vulnerable position of research subject), the legal basis for processing is legitimate interest if permitted by the results of a balance test. Where the legitimate interest of the controller is the basis for processing, legitimate interests include scientific research, customer relationship management, customer communications and marketing, events, business planning, reporting, analytics and risk management, and recruitment as well as other uses that are in our legitimate interest under applicable law. You may at any time prohibit the processing of your personal data for direct marketing and profiling purposes.

We also process personal data based on business agreements. Therefore, the agreement as a basis for processing consists of our general terms and conditions and data protection policy, as well as any special terms or other agreement applicable to the individual case in question. These are pursuant to our legitimate interest and/or the user’s consent.

TRANSFERS OF YOUR PERSONAL DATA

We may disclose your personal data to third parties solely as stated below in this Policy, or as obligated by mandatory law.

Opting-out from e-mail/SMS based marketing. You may opt-out from brand marketing e-mails by following the guidance in those e-mails (typically provided via “unsubscribe” link) or by contacting the respective brand/group company as set forth in the e-mail and in their web site.

Service providers and other authorized third parties. We may transfer your personal data to authorized third parties who process personal data on behalf of Glucomodicum for the purposes described in this Policy, such as e.g., technical, logisticsmarketing and other service providers. Such parties are not permitted to use your personal data for any other purposes than for what your personal data was collected, and we require them to act consistently with applicable laws and this Policy as well as to use appropriate security measures to protect your personal data.

International transfers. Our products and services may be provided using resources and servers located in various countries around the world. Therefore your personal data may be transferred outside the country where you use our services, including to countries outside the European Economic Area (EEA), where the level of data protection may not be deemed adequate by the European Commission. In such cases we take steps to ensure that adequate protection for your personal data is provided as required by applicable laws. For international transfers of your personal data, we generally rely on agreements that are based on the Standard Contractual Clauses (“SCCs”) of the European Commission. You may find the SCCs here.

Other disclosures. We may disclose and otherwise process your personal data in accordance with applicable laws to defend Glucomodicum’ legitimate interests, for example, in civil or criminal legal proceedings.

Mergers and Acquisitions. If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers, for the purposes of such transactions.

DATA CONCERNING MINORS

Glucomodicum does not seek to collect any information from or engage in any transactions with persons under the legal age in their respective country. We reserve the right to block the service from any person who is or whom we reasonably suspect of being a minor. If you are a minor but have your legal guardian’s consent, you must be able to prove that such consent exists upon request.

DATA QUALITY AND RETENTION

We take reasonable steps to keep the personal data we possess accurate and up-to-date and to delete out of date or otherwise incorrect or unnecessary personal data. We store your personal data only for a period necessary for the purpose in question or as long as required by applicable laws.

DATA SECURITY

Glucomodicum implements appropriate technical and organizational security measures to prevent and minimize risks associated with providing and processing personal data. Such security measures include, where appropriate, the use of firewalls, secure server facilities, encryption, implementing proper access rights management systems and processes, careful selection of processors, sufficient training of Glucomodicum’ personnel involved in the processing, and other necessary measures to provide appropriate protection for your personal data against unauthorized use or disclosure. Where appropriate, we may also take back-up copies and use other such means to prevent accidental damage or destruction of your personal data.

USE OF COOKIES AND WEB BEACONS

We may collect your personal data for various purposes as described in our cookie policy, using technologies such as cookies, pixels, beacons and similar technologies to collect information about your device. Each of our sites, applications and services is subject to our cookie policy.

For more information, read our cookie policy, which is available on the company’s website. You can also edit cookie-related settings and manage your cookie consent in cookie settings on the company’s website at or in the settings of your internet browser. You may edit your cookie preferences from the link on the bottom of the website. More detailed information about cookies is described in the cookie banner of our website.

Cookies are small text files that are stored in your browser. Some cookies are activated automatically because the online service needs them to function properly. We also use cookies to track the use of the service and to provide you with targeted content and relevant advertising.

We use cookies on our website to make the use of our services easier and technically smoother. Cookies help us obtain information about the number of visitors, the pages visited by visitors, and their browsers and operating systems. With this information, we can better understand the use of our services and our users so that we can better develop our services.

Our services use web analysis tools to collect analytics data and reports about visitors’ use of our website.

YOUR RIGHTS

You have the right to request information and access to the personal data we have collected from and of you. You also have the right to request that we replenish, rectify, anonymize or delete any incomplete, incorrect, unnecessary or outdated personal data we hold on you. However, we cannot delete such personal data that is necessary for compliance with binding legal obligations or if the personal data must be retained according to applicable laws. You have the right to request and receive the personal data we have collected on you in a commonly used and machine-readable form. In case you consider your personal data collected by us to be inaccurate, you do not wish your personal data to be deleted where the processing of your personal data has been deemed unlawful or the personal data is no longer necessary, or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.

You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Further, where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.

In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this Policy. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you. We encourage you to use available profile management tools for the above purposes as such tools often provide you with direct access to your personal data and allow you to effectively manage it. Please note that Glucomodicum may need to identify you and to ask for additional information in order to be able to fulfill your above requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.

COMPLAINT TO THE SUPERVISORY AUTHORITY

In the event you consider Glucomodicum’ processing activities of your personal data to be inconsistent with the applicable data protection laws or that Glucomodicum has not sufficiently ensured the realization of your rights, you may lodge a complaint with the local supervisory authority responsible for data protection matters.

THE CONTROLLER OF YOUR PERSONAL DATA AND CONTACT DETAILS

The data controllers responsible for the purposes of the applicable data protection laws are, as applicable:

GlucoModicum Oy

https://glucomodicum.com

Toinen Linja 7, 6th floor

00530 Helsinki, Finland

DATA PROTECTION RELATED MATTERS

In all data protection related matters, data subjects may contact Glucomodicum by using the following contact information:
sar@glucomodicum.com

CHANGES TO THIS PRIVACY POLICY

Glucomodicum may from time to time update and change this Privacy Policy. If the changes include new purposes of processing, Glucomodicum will give you prior notice of such changes and, where necessary, request your consent.