Privacy Policy

General Information

Your privacy and trust are, and have always been, a priority for Insulcloud S.L. and its subsidiaries, Insulcloud Delivery S.L.U. and Insulcloud Factory S.L.U. (hereinafter Insulcloud). We explain in a clear and accessible way how we use the personal information you provide through this website. Insulcloud guarantees that all appropriate measures have been adopted to ensure the security and protection of any personal data shared through the website.

This Privacy Policy governs the use of personal data collected through our websites insulclock.com, insulclock.es, insulcloud.com, insulcloud.es and tudiabetesbajocontrol.com, including all subpages and their versions in languages other than Spanish (hereinafter referred to collectively as the “website”, “our website” or “this website”). If you leave our website via a link or visit our pages on social media, you will also leave the scope of this Privacy Policy.

Because the services and products offered by Insulcloud through this website involve processing personal data, this Privacy Policy complements the Legal Notice and Terms of Use of the INSULCLOUD 360 SYSTEM. The INSULCLOUD 360 SYSTEM consists of a device that attaches to the insulin pen, a mobile application, and a web platform for healthcare professionals.

Please read this section carefully and, if you have any questions regarding how Insulcloud processes your data or about any other aspect of this Privacy Policy, feel free to contact our Data Protection Officer (DPO), who will get in touch with you as soon as possible.

Due to possible changes in legislation as well as internal organisational updates within Insulcloud, this Privacy Policy may be modified over time. We therefore recommend reviewing it periodically. However, if we consider that the changes introduced are significant, we will notify you using the contact details you may have provided.

If you disagree, in whole or in part, with any of the information detailed here or do not accept the provisions of our Legal Notice and Terms of Use, we kindly ask you not to use any of our services and to leave this website.

Data Controller

The information you provide through the mobile application will be processed under the responsibility of Insulcloud. To help you identify us and contact us if desired, we provide our details below:

• Owner: Insulcloud, S.L.
• Trade Name: Insulcloud
• Tax ID: B-87131454
• Headquarters: Calle Bravo Murillo 101, 2ª, 28020 Madrid (Spain)
• Registered Office: Avenida de Sabino Arana 8, 2ª, 48013 Bilbao, Bizkaia (Spain)
• Registered in the Commercial Registry of Bilbao, Sheet BI-73144, Volume 5838, Folio 198
• Medical Device Manufacturer Licence granted by the Spanish Agency of Medicines and Medical Devices (AEMPS): 8410-PS
• Email Address: info@insulcloud.com
• Data Protection Officer (DPO): The organisation has appointed a Data Protection Officer (DPO), who acts as the point of contact for any matter related to the processing of personal data. If you wish, you can contact them at: legal@insulcloud.com

What is Personal Information?

Personal data means any information relating to an identified or identifiable natural person. A person is considered identifiable if their identity can be determined, directly or indirectly, particularly through an identifier (for example: name, email address, or an identification number).

Collection and Use of Data

You do not need to register or provide any personal data in order to browse the website beyond those automatically collected through . The scope of data processed depends on how the user interacts with the functions of the website. However, some services require you to voluntarily provide certain personal data in order for us to provide the service: You do not need to register or provide any personal data in order to browse the website beyond those automatically collected through automatically collected. The scope of data processed depends on how the user interacts with the functions of the website. However, some services require you to voluntarily provide certain personal data in order for us to provide the service:

• Contact us. The website allows you to contact us to request additional information about our company or products. We only require your email address and a name, which we will use to respond to your enquiry. If you click on the CONTACT section
• If you send us your CV via email or through the CONTACT section provided on the website, and your profile matches an open position, your data will be incorporated into the Human Resources database managed by Insulcloud. Your data will be processed for recruitment purposes. If you do not want your data to be processed for this purpose, or you wish to exercise your rights, please contact Insulcloud in writing at the address provided above or via our Data Protection Officer.
• To provide you with a demo of the ENDO® Web Platform. If you are a healthcare professional, we offer you the possibility to access a simulator of our ENDO® Web Platform, where you can see how patient information is displayed. To do this, we need your full name, email address and phone number.

When submitting any personal information, you confirm that it is accurate, complete and freely provided, and you consent to its processing in accordance with this Privacy Policy. You also confirm that you understand and accept our Legal Notice and Terms of Use and our Cookie Policy. Please inform us of any changes to the data you have provided at legal@insulcloud.com

The website also automatically receives and collects information through cookies and other technologies: your domain name; browser type and operating system; web pages visited; links clicked; IP address; time spent on the website and/or using our services; and the referring URL or website that directed you to our site. This information is collected to help us manage, secure and improve our services, analyze their use, and enhance the user experience. We may combine automatically collected information with other information we hold about you. Please consult our Cookie Policy for further information.

Google® Services

On our website, we use Google® Analytics to obtain and analyze information about your browsing behavior. This digital tool, developed by Google®, provides analytics regarding audience and traffic on our website. Google® Analytics® does not collect data such as names, surnames, or postal addresses from which the connection is established. The information collected is related to the number of pages visited, language, browser used, internet service provider, and the IP address from which the user accesses, among others. Google® uses a cookie to collect information about your use of this website (including your IP address) and stores it in the United States. However, your IP address will be shortened (and therefore anonymized) before being transferred by Google® in member states of the European Union or in other states that are parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google® server in the United States and shortened there. Google® will analyze the collected information for the purpose of compiling reports on website activity and providing additional services related to website use. The IP address transmitted by your browser within the framework of Google® Analytics® will not be merged with other Google® data. Please refer to our Cookie Information for more information.

In addition to blocking all cookies in your browser, you can also prevent Google® from processing this data by downloading and installing the browser plug-in available through the following link.

As an alternative to the browser plug-in, especially for mobile device browsers, you can prevent future tracking by Google® Analytics® by setting an opt-out cookie, which will prevent the future collection of your data when visiting this website (the opt-out cookie will only remain effective in this browser and for this domain, so if you delete cookies, you will need to click the link again): Disable Google® Analytics®.

Furthermore, this website uses the Google® advertising tool Google® AdWords®, including its conversion tracking and remarketing features.

The remarketing tool allows us to show you personalized advertising on other websites you visit. To do this, Google® analyzes your use of our website and stores the corresponding ID in your browser. This ID allows us to assign you to a specific user group and recognize you when you visit a website that is part of Google®’s advertising network. These websites may then display advertisements related to your use of our website. At no point does Google® collect personal data from you during this process; the assignment occurs exclusively through your browser. The collected data is stored and processed in the United States.

We use conversion tracking to measure the success of our advertising for our services on other websites. When you click on one of our ads, a conversion cookie is generated. This cookie allows us to recognize that you arrived on our website via that ad. Using these usage statistics, we compile reports to evaluate the conversion rate of our ads. We do not receive any personal information about you. The conversion cookie set in your browser is unique and cannot be used by other Google® AdWords® clients for their statistics.

You can disable this remarketing by disabling this feature.

Both Google® Analytics and Google® AdWords® are tools developed by Google®. Since Google is a company located outside the European Union, we have ensured that it is a U.S. entity certified under the "EU-U.S. Data Privacy Framework". You can find more information about Google® Analytics® at Google® data protection declaration, and further information about Google® AdWords® by clicking here.

Facebook® Services

Our website uses Facebook® Pixels or Custom Audience. This is a function of Facebook®’s web analytics service. Facebook® pixels are invisible graphic files embedded on our website. When you visit our site, various information related to the pixel is stored in your browser. This allows us to understand which subpages you have visited. We share this information with Facebook® so that we can better tailor our ads to your interests and analyze the effectiveness of our Facebook® ads. Depending on your use of the website, you may be assigned to certain interest groups known as Custom Audiences. The information generated by cookies is usually transmitted to a Facebook® server in the United States and stored there. You can find more information about data collection using Facebook® tracking pixels here or here.

We have no influence over Facebook®’s data processing operations. Facebook® uses the data for advertising, market research and optimization purposes. Facebook®’s privacy policy applies in this regard. Please note that the use of these tracking methods may allow user identification across multiple websites. You can disable this feature in the settings of your Facebook® account for all devices you use.

Facebook® is a tool owned by Meta Platforms, Inc. Since Meta Platforms, Inc. is a company based outside the European Union, we have ensured that it is certified under the "EU-U.S. Data Privacy Framework". For further information, please consult the Privacy Policy and Meta Platforms, Inc. Terms of Service.

Children’s Data

This website is intended exclusively for users over 18 years old. Minors wishing to use services offered by this website must have prior consent from their parents, guardians, or legal representatives, who are solely responsible for any actions carried out by the minors in their care. If we detect that a minor is using the website, we will request authorization from their parents or legal guardians. Once consent is obtained, the parents or legal guardians may access the minor’s data and any account created by the minor.

Parents or legal guardians may request the termination of data processing for the minor at any time by requesting Insulcloud to delete the minor’s account, by sending an email to legal@insulcloud.com, or by sending a letter to Insulcloud S.L., Calle Bravo Murillo 101, 2ª, 28020 Madrid (Spain), along with a photocopy of their ID and a photocopy of the Family Book. We will delete the minor’s account, but we may retain general non-identified data for research purposes or any data we are legally required to keep.

Why Do We Use Your Information?

At Insulcloud, we use your personal information with the utmost care to ensure appropriate protection, strictly in accordance with applicable legislation, and as described below:

• To respond to your questions or technical support requests, including operational issues, incident resolution, or any other inquiries or feedback you wish to share.
• To send you updated information about treatment, diabetological education, healthy living, exercise and nutrition, if you wish.
• To send you personalized marketing communications based on your preferences. Don’t worry, you will always have the option to opt out of receiving these communications.
• To better understand how you use and interact with the website (including features and functionality), its performance and impact on users (including basic demographic data such as geographic location), in order to validate updates and ensure the website’s security and protection at all times.
• If you are a healthcare professional and request a demo of the ENDO® Web Platform, we will use your personal information to create a user account and contact you regarding your impressions of the INSULCLOUD® 360 SYSTEM.
• For product development, data analysis, surveys or statistical studies.
• To research, develop (including features and functionality), test and improve the website.
• We may be legally required to use and retain your personal information, for example, in the prevention, detection or investigation of crime, fraud or potential threats to individual safety, violations of this privacy policy, or as evidence in legal proceedings. Your personal information may be subject to the laws of other countries and accessible to government, courts, law enforcement or regulatory authorities in those countries. We may also use your personal information to comply with internal security audits or to protect data or any other issue we deem necessary. Such use will always be based on:
  • applicable laws, including those outside your country of residence;
  • a request from a court, law enforcement or regulatory authority, including those from outside your country of residence;
  • compliance with this Privacy Policy, our Legal Notice and Terms of Use and our Cookie Policy; and
  • protection of our rights, privacy, security or property, or those of any other person.

As mentioned previously, the website also receives automatic information. This information is collected to help us administer, protect and improve our services, analyze usage and enhance user experience. We may automatically combine the collected information with other information we hold about you. Please refer to our Information about Cookies for more information.

Do We Share Your Information?

We may share your personal information with our service providers, insofar as it is necessary to host, support or technically maintain the website.

If we provide personal information to our suppliers for the purpose of providing support, such third parties are contractually obliged to maintain confidentiality and protect your personal data, and to use it only as strictly necessary.

We may share your personal data with third parties (including Insulcloud affiliated companies) with whom we collaborate to market a product or service or to carry out joint activities or programs, including but not limited to research and/or development projects and/or statistical analysis. We may also share your personal data with other suppliers if you expressly request it.

We will not transfer your personal data to third parties, except in the context of the sale, merger or transfer of one of our product lines or of Insulcloud, so that the purchaser can continue to provide you with the information and services currently offered by Insulcloud. For the avoidance of doubt, we will not sell your personal data to third parties for commercial purposes and will only share it with third parties when you have given consent or when permitted by law.

Where Do We Store Your Information?

The personal data you provide to us, as well as the data generated by your use of the website, is securely hosted in the cloud by HIRUSEC S.L., Paseo Ubarburu 7 Trasera 4C, C.P. 20014 San Sebastián (Gipuzkoa-Spain).

We take measures to ensure that the information we collect is processed in accordance with this Privacy Policy and with the requirements of applicable law, regardless of the location of the data, and in line with the agreement that Insulcloud has entered into with HIRUSEC S.L.

We guarantee that, if we are required to provide your personal data to our current or future service providers for the purpose of supporting potential incidents relating to the website, such third parties will be obliged to maintain and protect the confidentiality of your personal data and to use it only to the extent that is absolutely and strictly necessary.

How Do We Protect It?

Given the “core” of Insulcloud, the protection of your personal data has always been, is, and will continue to be a key priority for our company. For this reason, we use and have implemented all legal, administrative and technical mechanisms necessary to ensure the protection of your personal data.

Your personal data is protected. At Insulcloud, we restrict our employees’ access to your personal data strictly to those cases or situations in which such access is necessary to provide you with a good service or to guarantee the security of the data, and they will only access the personal data needed to provide the specific service.

It is important that you bear in mind that no data transmission over the Internet is completely secure, and therefore we recommend that you take extreme care whenever you share personal information online.

At Insulcloud, we are here to help you at all times. If you become aware of or suspect that your personal data may have been compromised, we kindly ask you to contact our Data Protection Officer as soon as possible.

How Long Do We Keep It?

We will store and retain your personal data for as long as is necessary and reasonable in accordance with applicable law and business requirements. To determine these retention periods, Insulcloud will take into account local laws and contractual obligations. When we no longer need personal data, we will securely delete it from our records and databases.

We retain your personal data in order to provide you with a quality service and for legitimate and essential business purposes, such as maintaining the performance of the website, making data-based business decisions about new features and offers, complying with our legal obligations and resolving disputes.

At your request, we may delete or anonymise your personal data so that you can no longer be identified, unless we are legally allowed or required to retain certain personal data, including in the following cases:

• If there is any unresolved issue relating to your account, or any unresolved claim or dispute, we will retain the necessary personal data until the issue is resolved;
• When we are required to retain personal data to comply with our legal, tax, accounting or audit obligations, we will retain the necessary personal data for the period required by applicable law; and/or
• When it is necessary for our legitimate business interests, such as fraud prevention or maintaining the security of our users.

Your Rights

The applicable data protection legislation grants you a series of rights, which we at Insulcloud are committed to respecting and guaranteeing that you can exercise at any time.

• You have the RIGHT OF ACCESS to know whether Insulcloud is processing your personal data or the data of a person you legally represent, as well as to exercise control over such data, to know the purposes for which we process it, how we handle your personal data at Insulcloud, and any other information you may request in this regard. You have the right to access, free of charge, the personal data we hold about you. To do so, please contact us at contact us. We will ask you to properly identify yourself by providing proof of identity, since we must verify your identity before providing you with your personal data. Once the identity verification process has been completed, we will provide you with this information as soon as possible and, in any event, within no more than one month (30 days) from the date on which we receive your request.
• You also have the RIGHT TO RECTIFICATION of your personal data, meaning you have the right to modify or request that we modify any personal data that is inaccurate or incomplete. You may request this rectification by contacting us at contact us, indicating which data you wish to rectify and the correction to be made, and enclosing supporting documentation, since we must again verify your identity. Once we receive your request, we will rectify your data within a period not exceeding 10 days.
• You also have the RIGHT TO ERASURE, which means you may request the deletion of any of your data or any record we hold that is unnecessary or not relevant to the purpose for which it was collected and/or that may allow your identification by Insulcloud. The data or record will be blocked, that is, identified and reserved in order to prevent further processing. We will proceed to delete the personal data in respect of which this right is exercised within 10 days from receipt of your request and will notify you in writing of the deletion carried out. You may request deletion by contacting us at contact us, indicating which data is concerned.
• You also have the RIGHT TO RESTRICTION. Exercising THIS right to restriction means that, if you so request, we will cease to carry out processing operations on your personal data that would otherwise apply. In other words, we will not delete your data, but we will stop processing it as we have done until now. You may request restriction of processing by contacting us at contact us, stating which data is concerned. We will restrict the processing of the personal data in respect of which this right is exercised within 10 days from receipt of your request and will notify you in writing of the restriction applied.
• You also have the RIGHT TO OBJECT, which you may exercise at any time, meaning that you can object to Insulcloud continuing to process your personal data by contacting us at contact us. You will again be required to properly identify yourself, under the same conditions as for the other rights. Within a maximum period of 10 days we will stop processing your data, unless there are legitimate and compelling legal grounds for the processing that override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
• The GDPR also grants you the RIGHT TO DATA PORTABILITY, whereby you may request a copy of your personal data in electronic format so that you can transfer such data for use in the services of a third party. We will comply with the exercise of this right without undue delay and as soon as possible, taking into account technical feasibility. You may request data portability by contacting us at contact us.
• You also have the RIGHT NOT TO BE SUBJECT TO AUTOMATED DECISION-MAKING, which means you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

If you wish to exercise these rights in relation to the personal data of a minor, in addition to the proof of identity indicated above, your request must be accompanied by a copy of the family record book or a document proving that you are the minor’s legal representative, parent or legal guardian.

We also inform you that, if for any reason you are not satisfied with the way in which Insulcloud processes the personal data for which we are responsible, or if we have not properly addressed the exercise of any of the above-mentioned rights, you have the right to lodge a complaint before the National Supervisory Authorities: Germany, Austria, Belgium, Bulgaria, Cyprus, Croatia, Denmark, Slovakia, Slovenia, Spain, Estonia, Finland, France, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, United Kingdom, Czech Republic, Romania, Sweden, Iceland, Liechtenstein, Norway, Switzerland, Canada, Australia, Japan, South Korea.

If you wish to submit any type of request regarding the personal data that Insulcloud holds about you, please do not hesitate to contact our Data Protection Officer, who will get in touch with you as soon as possible.