Glu Privacy Statement
Effective Date: October 5, 2018 REV 3.0
Our Commitment to Privacy
Welcome to Glu, operated by T1D Exchange, Inc. ("T1D Exchange"), an independent nonprofit organization (501(c)(3)). T1D Exchange values the privacy of your Personal Information. This Privacy Statement is meant to inform you of T1D Exchange's data collection and disclosure policies and practices related to your Personal Information gathered by T1D Exchange, regardless of the medium through which we collect such information, including through our Glu website. By using Glu and/or participating in our research studies, you signify that you agree with this Privacy Statement. If you do not agree with this Privacy Statement, please do not provide us with any Personal Information and refrain from using Glu and/or participating in our research studies.
Storage of Personal Information in the US
All information gathered from you will be stored and processed in the United States. If you access Glu from a location other than the United States, your use of Glu constitutes consent to the transfer of your information to the United States. Note that US law may not offer the same privacy protections as the law of your jurisdiction.
Modifications and Updates to the Statement
T1D Exchange may periodically update this Privacy Statement. We reserve the right to change, modify, add, or remove portions of this Privacy Statement at any time. Changes to this Privacy Statement will be posted on Glu. Your continued participation in our research opportunities and/or use of Glu indicates your agreement with these modifications and updates. We will also attempt to notify you about significant material changes in the way we treat Personal Information by sending a notice to the primary e-mail address we have on file or by placing a prominent notice on Glu.
Nature of Information We Collect
T1D Exchange collects information that you provide to us or have authorized third parties, such as diabetes clinics or other health care providers, to provide to us. Examples of Personal Information that we collect may include, without limit, your name, contact information (such as physical address, telephone number and e-mail address), birth date, gender, race, medical treatment and condition information, personal health record, biospecimen data, clinical trial information, and other personally identifiable information. Together such information is referred to as "Personal Information" within this Privacy Statement. Note that we may collect "Personal Information" through any comments, statements, or materials you post on our site that contain such information.
T1D Exchange also collects Non-Personal Information and anonymous information from users, to be used in an aggregate fashion or with certain identifying data removed. For example, T1D Exchange may collect system-related information, such as an IP address, browser type and operating system type to be used for system administration purposes, to help diagnose problems with our servers, to monitor traffic patterns, to determine which services are used most frequently and to assess site usage.
How We Use This Information
T1D Exchange may use your Personal Information for lawful purposes, including, without limit, conducting research as authorized by you pursuant to a separate Research Consent, evaluating your Personal Information to determine which research opportunities are most relevant to you, contacting you to participate in research opportunities, "questions of the day," customer satisfaction services, and other services available through Glu, authenticating your identity, addressing technical and quality assurance issues, and updating records regarding your account and related purposes. T1D Exchange will also allow you to share certain of your Personal Information with other participants in Glu based on the personal privacy settings you establish in the course of administering your account.
Sharing Your Information
Presently, we do not intend to sell, rent, or share your Personal Information with third parties that are not affiliated with or providing services to T1D Exchange, unless otherwise authorized by you. T1D Exchange may use and disclose de-identified, anonymous information derived from your Personal Information for research and marketing purposes, and otherwise use or disclose such information to researchers, clients, business partners, and other third parties for such purposes as may be determined by T1D Exchange.
T1D Exchange may retain your Personal Information for as long as we deem reasonable and/or as long as the law requires. If you cease to participate in Glu or any related research, we will continue to handle your Personal Information in accordance with this Privacy Statement.
Links on Our Website
We may provide links to other websites and resources ("External Resources") that are not part of Glu. We cannot be responsible for the privacy policies, practices, or content of these External Resources. We encourage you to review the privacy policies and terms and conditions of such External Resources so that you understand how they collect, use and share your information. Please be aware that this Privacy Statement does not apply to Personal Information collected on websites or other External Resources that may be linked to or through Glu.
T1D Exchange may use "cookies" for the convenience of our users and to enhance your experience using Glu. A cookie is a small text file that is recorded either temporarily or persistently on your computer by a web page server and is not intended to deliver viruses or other harmful programs to your computer. One function of a cookie is to enable T1D Exchange to recognize a user without requiring the user to repeatedly log in when using Glu or other T1D Exchange websites. By relying on cookies, T1D Exchange is able to deliver a more efficient service that is more personalized for each user. Additionally, cookies allow T1D Exchange to monitor traffic patterns, website usage, and session information which help make Glu more useful.
Web browsers generally accept cookies automatically. If you prefer, you generally have the option of setting your browser to decline cookies. Alternatively, you may be able to modify your browser setting to notify you each time a cookie is created and permit you to accept or decline cookies on an individual basis or to accept cookies from web sites that meet certain disclosure and use specifications. Note that most functionality of Glu may be limited if you direct your browser to reject all cookies.
Some parts of our Glu website use web beacons. Web beacons are a type of technology placed on a website for the purpose of tracking activity on the site, including but not limited to the date and time of the visit, the pages visited, the referring web page, the type of browser, and other similar information.
T1D Exchange does not knowingly or specifically collect Personal Information from users under the age of 13 through Glu. If you are a minor over age 13, some portions of the Glu website will require consent from your parent or guardian before you may use it.
T1D Exchange has implemented security measures intended to protect your Personal Information both online and offline, including measures intended to restrict unauthorized persons from accessing Personal Information and encryption technologies used when transferring and receiving data provided through Glu. We also have security measures in place at our physical facilities to help protect against the loss, misuse, or alteration of Personal Information that we have collected from you at Glu. Although we have implemented various measures to help protect your information, T1D Exchange does not and cannot guarantee the security of any information.
Opt-Out and Access to Information
Participation in Glu and our research studies is voluntary. If you decide at any point that you no longer want to participate in Glu or a research study or do not want be contacted about opportunities to participate in research studies and other services offered through Glu, you may opt-out of future participation and request to be excluded from future opportunities by or sending an e-mail to firstname.lastname@example.org and identifying your opt-out preferences.
If you do not want T1D Exchange to share your Personal Information with third parties, or if you do not want T1D Exchange to use your Personal Information as described above, you may "opt-out" of such uses by T1D Exchange by contacting us as provided above. However, opting out does not affect any of T1D Exchange's rights to use Personal Information provided to T1D Exchange under any separate Research Consent or other consent or authorization that you provided to T1D Exchange, or as it relates to information that T1D Exchange has already shared with third parties or used in a research study or for other purposes authorized by you, or as relates to information which is anonymous or in which direct identifiers have been removed.
Through your Glu account, you will have access to Personal Information that you have provided to T1D Exchange through Glu. Also, at your written request, we will provide you with access to such other Personal Information held by T1D Exchange. You may correct, amend, or delete Personal Information available through your Glu account. At your request and subject to applicable law, T1D Exchange will correct, amend, or delete such Personal Information or delete such Personal Information that is not available through your Glu account, but is otherwise held by T1D Exchange, where it is inaccurate, except where the burden or expense of providing access is disproportionate to your privacy concerns, or where the rights of persons other than you would be violated.
Questions and Comments
We welcome and thank you for your comments, questions, and suggestions. You are encouraged to direct any comments and questions relating to this Privacy Statement and our use of your information to privacy officer email@example.com or in writing to T1D Exchange, Inc., 11 Avenue De Lafayette, Boston, MA 02111. Those communications themselves, however, do not alter the terms of this Privacy Statement. Your use of Glu and related services are subject to this Privacy Statement, as posted on the Glu site, and may be changed by T1D Exchange from time to time.
Any questions or concerns regarding the use or disclosure of Personal Information should be directed to T1D Exchange at the address given above. T1D Exchange will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Statement. For complaints that cannot be resolved between T1D Exchange and the complainant, please see the Dispute Resolution section of the Glu Terms and Conditions of Use.
This Privacy Statement shall be governed by the laws of the State of Massachusetts, without regard to conflicts of law principles, and exclusive jurisdiction and venue for any dispute arising out of this Privacy Statement shall be the state courts or district federal courts of Massachusetts