Last Updated: February 2022

Welcome to the BlueStar app (the “Application”) owned by Welldoc, Inc. (“Welldoc”, “we”, “our” or “us”). Welldoc cares about your privacy and wants you to be familiar with how we collect, use, and disclose information about you. This Privacy Policy is designed to tell you about the practices regarding the collection, use, retention, and disclosure of information about you when using a BlueStar website, the Application, as well as through HTML-formatted email messages that we may send to you that link to this Privacy Policy (together, the "BlueStar Services").The BlueStar Services are operated as data controller by Welldoc. Please be sure to read this entire Privacy Policy before using the Application.

By registering for or otherwise using the Application, you (hereinafter “you” or “your”) acknowledge that you have read and understood the terms of this Privacy Policy. Specifically, by providing consent through the registration process, you authorize the collection, use, retention, and disclosure of information about you by Welldoc and its affiliates, business partners, and service providers for the purposes described in this Privacy Policy.

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. Essentially, it boils down to information about an individual, from which that individual is either directly identified or can be identified. It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).

Third Party Sites and Services

Please note that this Privacy Policy applies solely to the use of the BlueStar Services. If you use other websites or web applications operated by Welldoc, the privacy policy of those websites or applications would apply. This Application is intended for use by residents of the European Union.

This Privacy Policy does not address, and we are not responsible for privacy, information, or other practices of third parties, including any third party operating any site or on-line service (including, without limitation, any application) that is available through the BlueStar Services or to which the BlueStar Services contain a link. The availability of, or inclusion of a link to any such site does not imply endorsement of it by us or by our affiliates. We encourage you to become familiar with the privacy policy and terms of use of the other applications and websites that you use.

Information Collection

Information about you is collected through a variety of sources, such as directly from you and through your interaction with the BlueStar Services, from your meter, from your healthcare professional. Many functions of the BlueStar Services involve you directly submitting information so you may benefit from features or participate in activities using the BlueStar Services.

We are actively collecting the following categories of personal information:

• Contact information, such first name and last name, email address, and telephone number.
• Registration information, such as username and password.
• Demographic Information, country of residence, and age.
• Health-related data, such as blood glucose levels, diabetes type, diabetes treatment (medication, diet and/or exercise), and your choices regarding sharing health data for example, information related to meter readings, such as timestamp and value.
• Communications information based on our exchange with you, including when you contact us through the BlueStar Service or otherwise.
• Usage information, such as information about how you use the BlueStar Service and interact with us, and information you provide when you use any interactive features of the Service. Please also refer also to the section on Automatic Information Collection and Use for details on information collected passively during your use of the BlueStar Services.
• Device data, such as device identifier and device IP address.

We may combine this information with information we collect about you from other sources, such as from your health care provider, if you authorize this with your explicit consent. If you submit any personal information relating to another individual to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We will inform you when information you provide is required and when it is optional.

Automatic Information Collection and Use

The BlueStar Services automatically collect information about you and your use of it, such as what functions you use, and how you interact with it. For example, the Application analyzes your blood glucose levels that you enter or allow to be imported from a meter and based on those entries determines if there are patterns. We may also automatically collect information about you from website interaction, analytics partners, and other parties. Such information is used to help provide services, make notifications, and generally understand and improve the BlueStar Services. For example, we may receive information about your interactions with the Application so that we may determine the effectiveness of our services. The Application creates and sends information about your use of the Application (such as the functions you use) and your device (such as its model number, version, and device identifier) to our service providers, which compile the usage data into aggregate and statistical reporting for our use in managing the quality and performance of the Application. We use this data to troubleshoot the Application, to report on the level of service that we provide, to adjust to new usage patterns, and to otherwise improve our services. When you interact with the Application, your device may communicate other technical information that we use as part of our services. For example, as you use the Application, your device communicates with our technology, which in turn keeps records of your interactivity and requests for services and content to assist us in managing and improving the utility of the Application, and to conduct research and analysis on its use. The types of such interactive information may include the time and date, your Internet Protocol (IP) address, device identifier, Application version, requests made, and related identifiers to authenticate you to the Application, to analyze how the Application is used, to link information about how you use the Application with your account, and to help tailor our services. Our affiliates, business partners, and service providers may also use similar technical means for these purposes. To allow our systems and those of our service providers to communicate with your device and the Application, both the Application and your device transmit your device’s identifier and its current IP address. Some browsers have Do Not Track (DNT) features that let the user indicate a preference not to have online activities tracked. This feature is not technically available to the Application.

Please read the Cookie Policy in the BlueStar Web Application (“Web Application”) for detailed information about cookies and other tracking technologies used by the Web Application. The Cookie Policy includes information on how you may disable these technologies. If you do not disable them and continue to use the Web Application, we will infer your consent to their use.

How We Use and Disclose Information

We use your personal information only as permitted by law, for the purposes for which we collected. In respect of each of the purposes for which we use your personal information, the European data protection legislation requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below:

• Contractual Necessity, where we need to perform a contract, we are about to enter into or have entered into with you.
• Legitimate Interests, where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
• Compliance with Law, where we need to comply with a legal or regulatory obligation.
• Consent, where we have your specific consent to carry out the processing for the Purpose in question. Generally, we do not rely on your Consent as a legal basis for processing your health-related personal information or in the context of direct marketing communications.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information:

Purpose	Category(ies) of personal information involved	Our legal basis for this use of personal information
Creating your account and sending you important information regarding our relationship with you.	Contact information Registration information Demographic Information	Contractual necessity. We will inform you of any change in the BlueStar Services, changes to our terms, conditions, and policies, and other administrative information.
Service Delivery: To provide you the specific services that you select, such as health tracking, patterns, and reports. For your personal use and to interact with your healthcare provider such as your doctor. To send you communications regarding health adherence. For our interaction with you. To provide you with customer service. To respond to your inquiries and fulfill your requests, such as to send information, notifications, and other communications that you request.	Contact information Registration information Demographic Information Health-related data Communications information Usage information Device data	Consent (for health-related data) Legitimate Interests: we have a legitimate interest in providing you a good Service and communicate with you, including by sending you updates on our Services where you have shown interest in similar services from us
Research and Development: we may use your personal information for research and development purposes, including data analysis, audits, developing new products, enhancing the BlueStar Services, improving our products and services, identifying Application usage trends, and determining the effectiveness of our promotional campaigns.	Registration information Demographic information Health-related data Communications information Usage information Device data	Contractual necessity Legitimate interests: we have a legitimate interest in monitoring and ensuring the proper operation of our website and associated Services
Compliance and Protection comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements or our internal policies; enforce the terms and conditions that govern the Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.	Contact information Registration information Demographic Information Health-related data Communications information Device data	Compliance with Law Legitimate Interests: we have a legitimate interest in ensuring the ongoing security and proper operation of our BlueStar Services and associated IT services and networks

If you provide information through the BlueStar Services , we may combine such information with other information—such as from your caregivers, healthcare providers, and from our affiliates, business partners, and service providers—unless we specify otherwise.

We also disclose and share information collected through the BlueStar Services as follows:

• To our affiliates but only for the purposes described in this Privacy Policy but Welldoc is the party responsible for the management of the jointly-used Personal Information.
• To our third party partners with whom we offer a co-branded or co-marketed promotion, if you authorize us to do so.
• To our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, auditing, and other services, in order to enable them to provide services.
• As permitted by applicable law, to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We may also provide information about you and your use of the BlueStar Services to others or for other purposes if you authorize us to do so. For example, we may offer specific functions associated to specific business partners, for which more information about you may be exchanged. In such a case, we would inform you about the nature of the information being provided and receive your acceptance (which may be by selecting a button or engaging in other electronic actions that signifies your acceptance) before we exchange the additional information about you. we might directly ask you, or we might be able to rely on settings you have made to your account profile to authorize an information disclosure.

We may also use and disclose your information in other ways, after obtaining your consent to do so.

Also, where allowed by applicable law, we may use and disclose information that is not in personally identifiable form for any purpose. If we combine information that is not in personally identifiable form with information that is identifiable (such as combining your geographical location with your name), we will treat the combined information as personal information as long as it is combined.

Choosing to share your information with healthcare professionals

The BlueStar Services allow you to share your diabetes information with your healthcare professional. If you choose to share your data with your healthcare professional, your healthcare professional would be able to view all of the information from your blood glucose meter, insulin pump and/or continuous glucose monitor, as well as any other information you entered into the Application from the time you registered in the program. We do not have any control over the data that you choose to share with your Care Team. If you would like to stop sharing your information, then you will need to contact your Care Team directly.

OneTouch Reveal and BlueStar

Having a OneTouch Reveal account is necessary for us to provide the BlueStar Services. If you discontinue your OneTouch Reveal Account, your associated BlueStar account will be automatically discontinued. If you discontinue BlueStar account, your existing account with OneTouch Reveal will remain active and accessible to you, but no data will be further shared with BlueStar or with WellDoc, Inc., as was necessary to provide the BlueStar Services.

Security

We use reasonable organizational, technical, and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contacting Us" section below.

Similarly, when the Application communicates with our systems and with our analytics providers, the information is sent over encrypted communication channels. We take other reasonable steps to protect information about you, including protecting the information from loss, misuse, and unauthorized access, disclosure, or alteration. Please keep in mind that no website, web application, software, or supporting system is ever completely secure or error-free. If you have reason to believe that the security of your account has been compromised, or have any other related concerns, please contact Us immediately as described below.

Choices and Access

We may communicate with you through the BlueStar Services and by email. You may manage certain other ways in which we communicate with you. For example, you may subscribe or unsubscribe to certain communications from Us, such as for notifications and marketing. You may not unsubscribe from administrative messages that we may send, such as to alert you of changes in our Privacy Policy or Terms of Use.

You may opt-in to receive communications from us: We may ask for your consent to send informational messages to you such as messages to improve your understanding of the medications you are taking as well as conditions for which those medications are typically taken. If you no longer want to receive these communications from us, you can change your preferences in your My Account settings. You may also contact us as described below or follow the unsubscribe instructions included in the email messages you receive.

You may manage your account profile and related information by selecting the My Account tab in the Application or in the Web Application. If you have questions about managing the information about you, you may contact us as described below. We will try to comply with your request as soon as reasonably practicable.

Your rights - How you can access, change, or delete your personal information

European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take actions in relation to your personal information that we hold. If you would like to access, correct, update, restrict, or delete your personal information, object to our reliance on our legitimate interests as the basis of our processing of your personal information, or if you would like to request to receive an electronic copy of your personal information (to the extent these rights are provided to you by applicable law), please visit My Account in the Application or visit "Contacting Us" in the Application for our contact information. We will respond to your request as soon as reasonably practicable and no later than one month after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us as described below or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Retention Period

We retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the BlueStar Service to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require processing the personal information, we have collected about you, we will either delete or anonymize it. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Use by Minors

The BlueStar Service is not directed to individuals under the age of 18 in your country of residence, and we request that these individuals do not provide personal information through the BlueStar Service. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us as explained below under "Contacting Us". We encourage parents to talk to their children about their use of mobile applications and the Internet.

Cross-border Transfer

If you are a resident of the European Union, we will process your personal information primarily in the European Union. However, your personal information may be stored and processed outside of the European Union, in any country where we have facilities or service providers, for the purposes described in this Privacy Policy. If we transfer your personal information to another country, we will establish a valid mechanism to protect your personal information. Some non-European Economic Area (EEA) countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers of your personal information to countries not deemed by the European Commission to provide an adequate level of personal information protection, including the United States, the transfer will be performed (i) pursuant to the recipient’s compliance with standard contractual clauses, or Binding Corporate Rules; (ii) pursuant to the consent of the individual to whom the personal information pertains; or (iii) as otherwise permitted by applicable European requirements.

You may obtain a copy of these measures by contacting our data protection officer in accordance with the “Contacting Us” section below.

By using the BlueStar Services, you acknowledge that your personal information can be transferred to countries outside of your country of residence.

Sensitive Information

Notwithstanding the health-related functionality of the BlueStar Services and the corresponding provision of your health data, unless we specifically request or invite it, we ask you not to provide us with any other sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, criminal background or trade union membership) on or through the BlueStar Services (e.g., in the Logbook Notes) or otherwise to us. In those cases where we may request or invite you to provide other sensitive information, we will do so with your express consent. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our BlueStar Services.

Contacting Us

You can also contact Us if you wish to obtain further information about our practices with respect to service providers outside of your country or questions you may have about this Privacy Policy or the information practices of the BlueStar Services, please contact a representative at:

You may also contact our data protection officer responsible for your country or region, if applicable, at:

emeaprivacy@Welldoc.com.

Lodging a Complaint with a Regulator

You may, if applicable, lodge a complaint with a supervisory authority competent for your country or region. Please click here for contact information for such authorities.

Updates to this Privacy Policy

We may update this Privacy Policy when our update of the BlueStar Services affect the processing of your personal information. You will be prompted to read the updated Privacy Policy prior to continue using the Application. We also encourage you to read the Privacy Policy whenever you install an update to the Application. Please look at the top of this page to see when this Privacy Policy was last revised. Your use of the BlueStar Services following these changes indicates that you have read and understood the revised Privacy Policy.