Privacy/Cookies Policy

Effective date: 14^th November 2020

This Privacy/Cookies Policy explains how we handle the personal information that you provide to us on the FreeStyle Libre Web Site controlled by Abbott’s diabetes care division (“Abbott”, “we”, “our”) [https://Sample.Freestyle.Abbott] (including its subsidiaries and affiliates) which links to this Privacy/Cookies Policy (referred to as "Abbott Web Sites") and when you contact us by telephone. Abbott is responsible for the processing of and is the controller of your personal information under the UK Data Protection Act 2018.

This Privacy/Cookies Policy also describes how we collect and use your personal information, including health-related information, when you contact us through our customer support channels about our products or services or products or services of our partners and affiliates. It also describes the collection of certain other types of technical and web browsing information through cookies and similar technologies on Abbott Web Sites.

This Privacy/Cookies Policy does not apply to personal information collected from Abbott Web Sites that do not link to this Privacy/Cookies Policy, or to third-party web sites to which Abbott Web Sites may link. Your use of Abbott Web Sites, which link to this Privacy/Cookies Policy is subject to this Privacy/Cookies Policy and the Terms of Use.

Please read this Privacy/Cookies Policy before using Abbott Web Sites or providing personal information to us.

Types of Information Collected

• How does this Privacy/Cookies Policy define "personal information"?
• What types of information does Abbott collect online?

Collection of Personal Information

• Does Abbott collect “sensitive” Personal Information?
• How does Abbott use personal information that I have provided?
• Will Abbott combine personal information I provide to Abbott with other personal information about me?
• What choices do I have about how Abbott collects and uses personal information about me?
• Does Abbott share personal information with third parties?
• Who within Abbott will have access to personal information about me?
• How does Abbott secure personal information?
• Does Abbott transfer personal information to different jurisdictions?
• For how long will Abbott store my personal information?
• How does Abbott protect the privacy of children?
• How may I correct personal information or delete it from current customer records?

Use of Cookies and Other Tracking Technologies

• Why do Abbott Web Sites use “cookies” and other tracking technologies?
• What types of cookies and other tracking technologies do Abbott Web Sites use?
• What choices do I have about Abbott’s use of cookies and other tracking technologies?

Your Rights

• What rights do I have in relation to my personal information?

Contact Information and Policy Updates

• How can I contact Abbott?
• How will I know whether Abbott has updated this policy?

I. Types of Information Collected

How does this Privacy/Cookies Policy define "personal information"?

"Personal information" means information that identifies you or could reasonably be used to identify you and which is submitted to us by you when using our Web Site or when you contact our customer support channels and/or collected by other Abbott Web Sites and maintained by Abbott in an accessible form. Examples of personal information include your name, your postal address, your e-mail address, and your telephone number.

What types of information does Abbott collect?

Personal Information You Submit: Abbott collects personal information that you enter into data fields on Abbott Web Sites.

For example, you may submit your name, postal address, e-mail address, payment details, date of birth and/or other information in order to place orders on our Web Site, receive information about our products and services (including software updates, special offers, product training, and other FreeStyle Libre related information that may be of interest), register for Abbott programs or webinars, use our customer support channels, or respond to Abbott surveys.

To protect your privacy, you should not provide Abbott with any information that is not specifically requested.

If you contact us through our customer support channels by phone, email or through social media or online chat (if available in your country of residence), we may collect a variety of personal information about you. We may collect any of the following pieces of information, depending on the nature of your request:

• your name, address, date of birth, country of residence, email address, phone number;
• whether you are contacting us on behalf of a user of our Web Site or someone that has used our products or services;
• details of your sensor, reader or meter, account information or other details of your use of products/services provided by Abbott, depending on the reason you contact customer support;
• if you use the FreeStyle App or LibreLinkUp App, information about your mobile device, including information about your operating system; and
• information about the issue for which you have contacted us, including records of our discussions and any follow-up where we contact you.

Failure to provide such personal information may mean that we cannot provide you with the product or service you have requested.

Passive Collection of Certain Other Technical and Web Browsing Information: Abbott Web Sites may collect information about your visits to Abbott Web Sites without you actively submitting such information.

This information may include, for example, your browser type and language, your operating system, your Internet Protocol (IP) address, the URLs of sites you visited before and after visiting the Abbott Web Site, the web search that landed you on the Abbott Web Site, web pages and advertisements you view and links you click on within the Abbott Web Site.

This information may be collected using various technologies, such as cookies, Internet tags, and web beacons. Your Internet browser also automatically transmits to Abbott Web Sites some of this information, such as the URL of the Web site you just visited and the browser version your computer is operating.

II. Collection of Personal Information

Does Abbott collect “sensitive” Personal Information?

In some jurisdictions and subject to your consent, Abbott Web Sites collect personal information, such as health related information. We may also collect sensitive personal information, including health-related information, if you provide that information to us through our customer support channels.

This information may be designated as "sensitive" under data protection or privacy laws. Abbott shall adopt additional measures as required by local law for the processing of such information. In addition, individual Abbott subsidiaries or affiliates may adopt measures to address local custom or social expectation about such information.

By providing us with sensitive personal information, where required by applicable law, you consent to Abbott collecting, transferring, storing and processing it

How does Abbott use personal information that I have provided?

Abbott will use the personal information you provide through Abbott Web Sites to respond to your questions and to provide you with efficient customer service. Abbott will use the personal information you provide to process and fulfil any orders you make on the Web Site (including to send you information about the ordering process by email, SMS or post), validate, facilitate and manage your customer account and to process and deal with your inquiries.

Abbott will use the personal information, including health-related information, you provide when you contact us through our customer support channels to provide you with customer support services.

We may also use this personal information for other business purposes, such as to offer you the opportunity to receive notices regarding Abbott’s products or services, to invite you to participate in surveys about our products, or to notify you about special promotions (if you have given your consent where required under applicable laws).

Your provision of personal information to Abbott is required to fulfil the terms of a contract you have with us to provide you with the product or service you have requested (such as when you place an order through our Web Site).

We also process personal data where necessary for compliance with our legal obligations, such as those in relation to product or medical device safety. We may also process your personal information, including health-relating information, where it is in our legitimate business interests to do, such as to provide you with customer support, to evaluate and improve our existing products and services and our Web Site, and to research and develop new products and services.

If required under applicable laws, we may rely on your consent to send you information about our products or services, to invite you to participate in surveys about our products, to notify you about special promotions, and to process data collected through cookies or similar technologies on our Web Site.

Will Abbott combine personal information I provide to Abbott with other personal information about me?

Abbott may combine the personal information that a customer provides on one Abbott Web Site with the personal information provided by that customer on other Abbott Web Sites.

Abbott may combine personal information that you provide to us online with our offline records.

Abbott may combine personal information that you have provided to us directly with records provided by third parties.

We use this consolidated information to help us better design Abbott Web Sites and Abbott products, to communicate information to you, to enhance our marketing and research activities, and to facilitate other business functions.

What choices do I have about how Abbott collects and uses personal information about me?

You may always limit the amount and type of personal information that Abbott receives about you by choosing not to provide the information or enter any personal information into forms or data fields on Abbott Web Sites. Some of our services can only be provided to you if you provide us with appropriate personal information. Other parts of Abbott Web Sites may ask whether you wish to opt into or opt out of our contact lists for offers, promotions and additional services that may be of interest to you.

Does Abbott share personal information with third parties?

Abbott will not sell or license your personal information to third parties except in connection with the sale or transfer of a product line or division, or in connection with a joint marketing programme or if you have given your consent, if required under applicable laws.

Abbott may share your personal information with third parties with whom Abbott is jointly marketing a product or service or jointly conducting a programme or activity. It is Abbott’s practice to notify you if you are registering for a programme that will be conducted in conjunction with another company that may require access to your personal information.

Abbott may also share your personal information with vendors with whom Abbott contracts to carry out business activities for Abbott (such as customer support services, delivery services, online payment services and fraud detection services). If Abbott provides your personal information to vendors to assist us with our business activities, it is Abbott’s practice to require those vendors to keep your personal information confidential and to use your personal information only to perform functions for Abbott.

Abbott may share your personal information with a third party in connection with the sale or transfer of one of its product lines or divisions so that the buyer can continue to provide you with information and services.

Abbott reserves the right to disclose your personal information to respond to authorised information requests from government authorities or law enforcement agencies, to address national security situations, or when otherwise required by law. In certain cases, Abbott may also disclose your personal information to legal advisers and auditors.

Who within Abbott will have access to personal information about me?

Personal information can be accessed by a restricted number of Abbott employees.

We train our employees about the importance of privacy and how to handle and manage customer data appropriately and securely.

How does Abbott secure personal information?

It is Abbott’s practice to secure each web page that collects personal information; however, the confidentiality of personal information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health.

Abbott cannot guarantee that unauthorised third parties will not gain access to your personal information; therefore, when submitting personal information to Abbott Web Sites, you must weigh both the benefits and the risks.

In addition, Abbott Web Sites covered by this Privacy/Cookies Policy will display a warning whenever you link to a Web site that is not controlled by Abbott or subject to an Abbott Privacy/Cookies Policy; you should check the privacy policies of such third-party Web sites before submitting personal information.

Does Abbott transfer personal information to different jurisdictions?

Abbott stores data on secured servers in several countries around the world. Please be aware that information you provide to us or we obtain as a result of your use of the Abbott Web Sites may be processed and transferred to countries other than the country in which you are resident, including the United States.

The privacy and data protection laws in such countries may not be equivalent to the laws in your country of residence. By using and participating in any Abbott Web Sites or providing us with your information, you consent to this collection, transfer, storage, and processing of information to and in such countries.

We transfer personal information outside of the European Economic Area (“EEA”) and the UK to third countries which do not offer the same level of protection.

To safeguard your personal information, we will only make such transfers on the basis of (i) a decision by the European Commission that permits this, or in the case of the United Kingdom, a decision by the Information Commissioner’s Office (ICO), or (ii) subject to EU-approved Standard Contractual Clauses or for the UK, an ICO approved a form of data transfer agreement.

Please note Abbott has entered into data transfer agreements based on the EU Standard Contractual Clauses to transfer your personal information from the EEA to third countries, which includes the United States.

To request a copy of the EU Standard Contractual Clauses which we use to export your personal information from the EEA, please contact our EU DPO (details below).

We may provide, or use other third parties to provide, customer support services in the EEA, UK, US or North Africa depending on your country of residence. When you call our customer support channels, your call will initially be routed through a call centre in your region.

If we are unable to resolve your issue at this initial stage, we may need to escalate your request to a team located in a different region.

This means that your personal information may be accessed initially within your geographic region and subsequently from another country that is outside of your region. Your personal information will be stored on a secure cloud-based data management system which has role restricted access.

For how long will Abbott store my personal information?

Your personal data will be stored for as long as it is needed to deliver and make available to you the app, service or product that you have requested, or in accordance with any legal requirements, including in relation to product and medical device safety. For further information, please contact or our EU-DPO office using the details below.

How does Abbott protect the privacy of children?

Abbott does not knowingly collect or use any personal information from children on Abbott Web Sites. We do not knowingly allow children to order our products, communicate with us, or use any of our online services.

If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.

How may I correct personal information or delete it from current customer records?

In accordance with local legal law, you may request that we remove your personal information from our current customer records or that we amend your personal information. Please notify us of your wishes by contacting us in one of the ways specified below. For our record keeping purposes, we will retain certain personal information you submit in conjunction with commercial transactions.

III. Use of Cookies and Other Tracking Technologies

Why do Abbott Web Sites use “cookies” and other tracking technologies?

A “cookie” is a file that our webserver may send to your computer when you access an Abbott website. This file is then stored on your computer. After you have entered personal information into a form or data field on an Abbott website, Abbott may use cookies and certain other technologies to allow that Web site to "remember" your personal preferences, such as sections of that Web site that you visit frequently and, if you choose, your user ID.

Passive information collection technologies can make your use of Abbott Web Sites easier by allowing Abbott to provide better service, customise sites based on consumer preferences, compile statistics, analyse trends, and otherwise administer and improve Abbott Web Sites. Certain features of Abbott Web Sites may not work without use of passive information collection technologies.

You can also learn more about cookies by visiting www.allaboutcookies.org (this website is available in English, German, Spanish and French).

What types of cookies and other tracking technologies do Abbott Web Sites use?

Abbott Web Sites use “session” cookies.

Session cookies are temporary bits of information that are erased once you exit your web browser window or otherwise turn your computer off. Session cookies are used, for example, to improve navigation on our web sites, block visitors from providing information where inappropriate (the site "remembers" previous entries of age or country of origin that were outside the specified parameters and blocks subsequent changes) and to collect aggregated statistical information.

The list of cookies that are used on the FreeStyle Libre website is available here.

Abbott Web Sites may use “persistent” cookies. Persistent cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie.

Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., passwords), helping to determine what areas of the web site visitors find most valuable, and customising the web site based on your preferences on an ongoing basis.

Persistent cookies placed by this site on your computer may hold personally identifiable information, but only if you have registered or have otherwise consented to the retention of personally identifiable information you have provided at the site. Otherwise our site's server only knows that an unidentified visitor with your cookies has returned to the site.

Abbott Web Sites may use “web beacons” (also known as internet tags, single-pixel GIFs, clear GIFs, and invisible GIFs) A web beacon is a tiny graphic on a web page or in an e-mail message that is used to track pages viewed or messages opened. Web beacons tell the web site server information such as the IP address and browser type related to the visitor's computer.

Web beacons may be placed on online advertisements that bring people to our site and on different pages of our site. Web beacons provide us with information on how many times a page is opened and which information is consulted.

What choices do I have about Abbott’s use of cookies and other tracking technologies?

You can choose to enable or disable the use of cookies and other tracking technologies on Abbott web sites. Exactly how these choices are presented to you and the process for making such choices may vary by web site.

On some Abbott Web Sites, you may be asked to explicitly consent to the use cookies and/or other tracking technologies on that web site. Cookies that are necessary to the operation of the site and to the provision of the services you have requested will continue to function regardless of whether you have provided consent. Other types of cookies and tracking technologies will be turned off until you provide explicit consent. As a result, the functionality of the site may be reduced until you choose to provide explicit consent.

On some Abbott Web Sites, you may be provided with preference questions or boxes allowing you to indicate that you do not want that web site to use cookies or other tracking technologies that are not necessary to the operation of the site. If you choose to exercise this opt-out option, the functionality of the site may be reduced as a result.

Some Internet browsers allow you to limit or disable the use of cookies and other tracking technologies. Please refer to the information provided by your Internet browser for instructions on how to do so (generally found under a “Help” menu).

IV. Your Rights

What rights do I have in relation to my personal information?

The applicable data protection law grants you comprehensive data protection rights to your personal information.  These are:

• The right to rectify or erase any wrong or incomplete personal data that Abbott holds about you;
• The right to opt out at any time of any marketing material from us. This will be noted at the bottom of any email you receive from us;
• The right to access the personal data that Abbott holds about you;
• The right, in some cases, to object to the processing of your personal data on legitimate grounds;
• The right not to be subjected to automated decision making intended to evaluate certain personal aspects relating to you, such as analytics based on conduct. Please refer to the cookies section of the privacy notice for more information on how to exercise this right if it is indicated that cookies are being used;
• Where you have provided your personal data to us with your consent or as part of a contract, the right to the portability of that personal data to another person or, if it’s technically feasible for us to do so, to another company;
• The right to lodge a complaint with your national data protection supervisory authority or to receive compensation for any damage you suffer; and
• The right to withdraw your consent to Abbott’s processing of your personal data, without detriment or negative consequences.

Please note that these rights may be restricted according to the applicable data protection regulations or may depend on additional requirements.

V. Contact Information and Policy Updates

How can I contact Abbott?

If you have questions about the use, amendment, or deletion of personal information that you have provided to us, or if you would like to opt out of future communications from an Abbott business or a particular Abbott programme, please contact us by clicking on the "Contact Us" link on the Web site you are visiting or by e-mailing us at webmaster@abbott.com. Alternatively, you may send a letter to the following address:

Abbott Laboratories

Attention: Public Affairs, Department 383

100 Abbott Park Road

Abbott Park, IL 60064-6048

United States

In all communications to Abbott, please include the e–mail address used for registration (if applicable), the Web site address or the specific Abbott program to which you provided personal information (e.g. Abbott.com, etc.), and a detailed explanation of your request.

Data Protection Officer: If you have any queries in relation to the processing of your personal information please contact our EU DPO at www.eu-dpo.abbott.com.

If you would like to delete, amend or correct your personal information and are contacting us by e-mail, please put "Deletion Request" or "Amendment/Correction Request", as applicable, in the subject line of the e-mail. We will do our best to respond to all reasonable requests in a timely manner.

How will I know whether Abbott has updated this policy?

Without prejudice to your rights under applicable law, Abbott reserves the right to amend this Privacy/Cookies Policy without prior notice to reflect technological advancements, legal and regulatory changes and good business practices. In certain jurisdictions, registered users will be notified by email of any changes and relevant information will be posted on the Abbott Web Site.

If Abbott changes its privacy practices, an updated version of this Privacy/Cookies Policy will reflect those changes and we will notify you of such changes by updating the effective date at the top of this Privacy/Cookies Policy.