Effective date: January 29th, 2021

Gojji Inc., (“us”, “we”, or “our”) operates the gojji.com website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. By using the Services, you agree to the terms of this Privacy Policy. If you have any questions or concerns about this Privacy Policy, or about the way your information is collected and used, please email us at info@gojji.com

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from gojji.com

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Cookies and Usage Data

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Use of Data

Gojji Inc. uses the collected data for various purposes:

• To provide and maintain the Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer care and support
• To provide analysis or valuable information so that we can improve the Service
• To monitor the usage of the Service
• To detect, prevent and address technical issues

How we use your personal data

1. In this Section we have included:
   • the general categories of personal data that we may process;
   • in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
   • the purposes for which we may process personal data; and
   • the legal bases of the processing.
2. We may process your personal data provided in the course of the use of our Services (“Service Data”). The Service Data may include name, email address, gender, date of birth, biometric data and health data and any other submitted or uploaded information. The source of the Service Data is you or your healthcare provider including device, activity, food or health data you share with our Services, such as from blood glucose meters, fitness trackers, or third party services.The Service Data may be processed for the purposes of providing our Services, analyzing the use of our Services for product development, informing you about product news, informing you about product issues, providing information we believe is of interest to you and communicating with you. If you are a private person signing up directly to our Services, the legal basis is your consent. If you are a data controller representing data subjects, the legal basis for our processing is legitimate interest.
3. We may process personally identifiable data about your use of our website and Services (“Usage Data”). The Usage Data may include your IP address, geographical location, browser type and version, device make and model, operating system, referral source, length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your service use. Usage Data is captured by our analytics tracking systems, which includes the use of cookies (see Sections 15-18). Usage Data may be processed for the purposes of analyzing the use and troubleshooting of the website and Services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and Services.
4. We may process personally identifiable data in our monitoring of network traffic of our website and Services (“Traffic Data”). The Traffic Data may include your IP address, browser type and version, operating system, and referral source. Traffic Data may be processed for the purposes of analyzing the use and troubleshooting of the website and Services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and Services.
5. We may process access information (“Audit Log Data”) regarding who has accessed and processed your Service Data and any access or processing you have made to other people’s Service Data. The Audit Log Data may include identification of the data subject, who has accessed the Service Data, when it was accessed, how it was accessed, and changes to Service Data. Audit Log Data may be processed for the purposes of allowing investigations to be performed regarding who has accessed your and other people’s personal data. The legal basis for this processing is legal requirements, which includes but is not limited to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Swedish Patient Data Law (2008:355).
6. We may process your business related account data (“Business Account Data”). Business Account Data may include your name, email address and any other submitted information. The source of the Business Account Data is you, your employer or an industry partner of yours. The Business Account Data may be processed for the purposes of operating our website, providing our Services, ensuring the security of our website and Services, maintaining back-ups of our databases and communicating with you. If the processing is performed by contract between you (or your employer) and us and/or taking steps, at your request, to enter into such a contract, the legal basis for this processing is performance of contract. If the processing is performed to establish or maintain a business relationship, the legal basis for this processing is legitimate interest.
7. We may process information contained in any inquiry you submit to us regarding our goods and/or Services (“Inquiry Data”) via our website or Services. Inquiry Data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is legitimate interest to fulfil your inquiry.
8. We may process information relating to transactions, including purchases of goods and Services, that you enter into with us and/or through our website or Services (“Transaction Data”). Transaction Data may include your contact details, your payment details and the transaction details. Transaction Data may be processed for the purpose of supplying the purchased goods and Services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and legal requirements for proper accounting.
9. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“Notification Data”). Notification Data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
10. We may process information contained in or relating to any communication that you send to us (“Correspondence Data”). Correspondence Data may include the communication content and metadata associated with the communication. Correspondence Data may be processed for the purposes of communicating with you and record-keeping, e.g. for technical support or accounting purposes. Further, when you seek technical support from us, you understand and acknowledge that the individual(s) providing you with support may need to access your Service Data and Usage Data in order to diagnose the problem you are seeking support for; in this case, this information will only be used to help provide you with support. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users, which we believe will benefit you.
11. We may process information about you for keeping records of incidents or complaints (“Regulatory Data”). Regulatory Data may be processed for the purposes of establishing internal reports and records that may be made available to authorities upon their request. The legal basis for this processing is legal requirements, specifically the current Medical Device Directive (93/42/EEC) and the Medical Device Regulation as it comes into effect on May 26th, 2021.
12. We may process your personal data you provide to us when you submit feedback to Gojji about our services (“Feedback Data”). The Feedback Data may include name, age and any information uploaded by you. The source of the Feedback Data is you. Feedback Data may be processed in marketing material and for publishing on our social channels such as Facebook, LinkedIn, Twitter and Instagram. The legal basis for this processing is consent.
13. We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
14. We may process any of your personal data identified in this notice where necessary for the purposes of the protection of yours or others’ personal data. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
15. In addition to the specific purposes for which we may process your personal data outlined in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Providing your personal data to others

1. Gojji’s policy is to avoid disclosing your personal data to others. We will protect and consider your interests at all times. In some cases, listed below, we may nevertheless disclose your personal data.
2. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this notice.
3. We may disclose your Service Data to your healthcare provider when your diabetes devices are synced at your healthcare provider’s office, during your appointments.
4. We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary in order to provide the Services. However, Service Data enjoys additional restrictions and may not be disclosed to any such third party suppliers or contractors unless pseudonymized, e.g. encrypted by a security key managed by, and only by, Gojji. Please reach out to Gojji (see Section 21) to request a current list of Gojji’s suppliers and subcontractors that process your personal data.
5. We may disclose your de-identified data for study purposes and learnings. We will receive no financial payment for disclosure or receipt of information.
6. Financial transactions relating to our Services are handled by our payment services providers. We will share Transaction Data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. Please reach out to Gojji (see Section 21) to request a current list of Gojji’s payment services providers that process your personal data.
7. We may disclose your Inquiry Data to our service providers for the purpose of enabling them to deliver services to us so that we can offer, market and sell to you relevant goods and/or services.
8. We may disclose your personal data to Third Party applications such as the Apple HealthKit to which you have chosen, at your sole discretion, to share your personal data. We will not share this data to any Third Party applications without your consent. Once your data has been shared at your discretion to a Third Party application, we no longer control the use of, access to, or disclosure of that data from that application, so you should understand the terms of use and privacy policies for any Third Party applications prior to opting in and consenting to share data with them.
9. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Gojji’s right to processing of anonymized data

1. By submitting your personal data to us, we may permanently anonymize the personal data and use it for statistical analysis, clinical research, demographic analysis, profiling of user behaviors within the application and characteristics and to measure interest in and management of physical conditions and similar processing. Permanently anonymized data does not constitute personally identifiable information and is therefore not traceable back to you. Permanently anonymized data may be exported to any country in or outside the European Union, USA or elsewhere. Within the US, both anonymization using HIPAA “Safe Harbor” and tokenization using an Expert Determination method may be used to anonymize data.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Gojji Inc. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data

Legal Requirements

Gojji Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Gojji Inc.
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security Of Personal Data

1. We will take appropriate technical and organizational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
2. We will store all your personal data on secure servers. Should personal data be provided to us in physical form, it will be stored in secure manual record-keeping systems.
3. All personal data stored electronically will be stored by us in encrypted form.
4. Transactions that are sent to and from your client, e.g. computer or mobile app, are protected by encryption technology.
5. You should ensure that your password(s) of our Services is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our Services confidential. We will not ask you for your password (except when you log in to our Services).

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

• Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Social Media

We may use and disclose your personal information to facilitate social media sharing functionality that you initiate. If you choose to engage in social sharing, your personal information may be shared with your friends, contacts or others associated with your social media account, with other Services users, and with your social media account provider. By contacting us via social media, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy.

We do not share any of your personally identifiable information, including your search history or health information, with social media platforms. See the policies of each social media platform for additional information.

Fraudulent Sites, Spam & Phishing

Please be aware that there may be fraudulent websites or companies that illegally use our logo, name and/or other aspects of our brand. Gojji Inc. is in no way associated with any fraudulent websites or companies. These sites may circulate their presence via spam email, telecommunication or through other fraudulent phishing, spamming or scamming practices.

These sites and companies have not been authorized by Gojji Inc. to use our logo, name and /or other aspects of our brand and we work diligently to identify their source and have them shut down. If you are in receipt of this type of spam email or call, to help protect your privacy, you should avoid replying to it, disclosing personal private information, or forwarding it to other people.

If you are concerned that a website, email or call may be fraudulent, please email us at info@gojji.com with your concerns.

Personal data of children

1. Our Services are targeted at persons of all ages. For children younger than 16 years, a parent’s or legal guardian’s consent is required in order to use our Services.
2. If we have reason to believe that we hold personal data of a person under the age of 16 in our databases without the appropriate consents, we may delete that personal data.

Notice to California residents

1. The California Consumer Privacy Act (CCPA), effective January 1, 2020, has specific protections for the personal data of California residents. Notices regarding these protections are included in this section.
2. Categories of personal information collected and/or disclosed by Gojji include those identified above in this privacy notice. Gojji is obligated to hold personal health information confidential under the California Confidentiality of Medical Information Act (CMIA) and, where applicable, the Health Insurance Portability and Accountability Act (HIPAA). We have not sold your personal data in accordance with CCPA regulations since enactment and do not intend to “sell” your personal information as defined under the CCPA.
3. California consumers have the right to request disclosure regarding the personal information (“PI”) that a business has collected about the consumer, as well as any business sale of her or his PI.
4. California consumers have a right not to be discriminated against for exercising any rights under CCPA.
5. California consumers may request deletion of their personal data. If Gojji holds your personal data on behalf of a clinic that uses Gojji services to help patients manage their diabetes, then please work through your clinic for deletion.
6. California consumers can direct requests or inquiries to info@gojji.com.
7. An “Authorized agent” as defined by CCPA can make a request on a person’s behalf, in accordance with CCPA regulations and guidelines.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: info@gojji.com