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Privacy Policy

1. INTRODUCTION

At PT Carepedia Inovasi Kesehatan (“GLUCOCARE” “us,” “we,” or “our”), our mission is to unlock human performance. We exist to improve your life, not invade it. We believe this should be the standard for all companies providing wearable devices. We take your privacy seriously and want you to understand how we use, collect, and share Personal Data, and the measures we take to protect your Personal Data.

This Privacy Policy applies to Personal Data we collect about members and other consumers who interact with GLUCOCARE or use our services, including by visiting our websites or our social media pages, or using our mobile apps, the GLUCOCARE Strap or another GLUCOCARE device (collectively, the “Services”). This Privacy Policy does not cover the practices of companies that we do not own or control, or people that we do not manage. We are not responsible for the policies and practices of any third parties, and we do not control, operate, or endorse any information, products, or services that may be offered by third parties or accessible on or through the Services.

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2. HOW WE COLLECT PERSONAL DATA

We collect Personal Data about you from:

  • Yourself, when you provide such information directly to us, such as when completing your profile;

  • GLUCOCARE Strap or another device that you wear;

  • Automatic data collection, such as Cookies, local storage objects, web beacons, and other similar technologies in connection with your use of the Services;

  • Customers and partners, such as employers, insurance companies, coaches, teams, or other organizations that engage with our Services;

  • Marketing and advertising partners, such as companies that have entered in joint marketing relationships with us or assist us with marketing or promotional services, which may provide us with data related to how you interact with our Services, advertisements, or communications;

  • Social media, other third-party platforms, and linked accounts, devices, or features, if you interact with our pages on social media sites, post content to their sites using the Services, sign into the Services through a third-party site or service, or otherwise link accounts, devices, or features to your GLUCOCARE account; and

  • Data providers, such as information services and data licensors, when we supplement your data.

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3. PERSONAL DATA WE COLLECT

We may collect the following types of Personal Data:

  • Contact details, such as your first and last name, email and mailing address, and phone number;

  • Profile data, such as username and password that you may establish to create a GLUCOCARE account, as well as any photographs or information you choose to include in your GLUCOCARE profile;

  • Communications that we exchange with you, including when you contact us via email, web app, or mobile app with questions, feedback, or reviews;

  • Wellness Data, such as resting heart rate, heart rate variability, skin temperature, blood oxygen saturation level and acceleration; metadata on workouts and sleep; the type of physical activity you engage in and the duration of your activity; data reflecting strain and recovery; your physiological profile, including birthday, gender identity, weight, height, fitness/athlete level (e.g., professional or recreational); and details you choose to submit about your diet, medications, and female health tracking. We may use certain of this information to customize your experience with us as part of our Services;

  • Payment and transactional data needed to complete your orders on the website or through the Services (including name, email address, payment card information, bank account number, billing information) and your transaction history, although GLUCOCARE does not have access to payment card numbers. Our payment processors will collect the financial information necessary to process your payments in accordance with the payment processor’s respective services agreement and privacy policy;

  • Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them (e.g., the marketing emails that you open and the links within them that you click);

  • Device data, such as your computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP Address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area;

  • Geolocation data, such as GPS, IP Address, and movement on certain exercise types if you give permission for GLUCOCARE to do so; and

  • Online activity data, such as pages or screens you view, how long you spent on a page or screen, the website you visited before visiting our website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

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4. COOKIES AND SIMILAR TECHNOLOGIES

GLUCOCARE uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, as well as to analyze trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

Cookie Usage and Type. GLUCOCARE uses the following Cookies:

  • Essential Cookies: Essential Cookies are required for providing you with features or Services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and Services unavailable.

  • Functionality Cookies: Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (e.g., your region).

  • Performance/Analytical Cookies: Performance/Analytical Cookies allow us to understand how users use our Services by collecting information on how often a user engages with a particular feature of the Services. We use these aggregated statistics internally to improve the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses Cookies in connection with its Google Analytics services. For more information on how Google uses this information, click here.

  • Marketing Cookies: Marketing Cookies collect data about your online activity and identify your interests so that we and our advertising partners can provide marketing that we believe is relevant to you. For more information, please see the section below titled “Interest-based advertisements.”

Online tracking opt-outs. There are a number of ways you can opt out of certain interest-based advertising and other online tracking activities, which we have summarized below.

  • Blocking Cookies in your browser. Most browsers let you remove or reject Cookies, including Cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept Cookies by default until you change your settings. For more information about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

  • Blocking advertising ID use in your mobile device settings. Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of your advertising ID associated with your mobile device for interest-based advertising purposes.

  • Using privacy plug-ins or browsers. You can block our websites from setting Cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party Cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

  • Visiting our OneTrust Privacy Preference Center. You can click here to customize your Cookie consent preferences.

  • Platform opt-out.

  • Some third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors, and research firms, allow you to opt-out directly by using their opt-out tools. Some of these providers, and links to their opt-out tools, are:

  • Advertising industry opt-out tools.

You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

Please note that some opt-out features are Cookie-based, meaning that when you use these opt-out features, an “opt-out” Cookie will be placed on your computer or other device indicating that you do not want to receive interest-based advertising from certain companies. If you delete your Cookies, use a different browser, or use a different device, you will need to renew your opt-out choice.

Opting out of interest-based advertising does not mean that you will no longer receive online ads. It only means that such ads will no longer be tailored to your specific viewing habits or interests. You may continue to see ads on and about the Service.

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5. HOW WE USE PERSONAL DATA

We process Personal Data to operate, improve, understand, and personalize our Services. We use Personal Data for the following purposes:

Service delivery, including to:

  • Provide, operate, improve, develop, understand, and personalize the Services and our business, including testing, research, analysis, and product development;

  • Satisfy the reason you provided the information to us, including responding to and fulfilling requests;

  • Communicate with you about the Services, including Service announcements, updates, or offers;

  • Provide support and assistance for the Services;

  • Create and manage your account or other user profiles;

  • Customize website content and communications based on your preferences; and

  • Process orders, memberships, or other transactions.

Research and development. We may create and use Aggregated Data, De-identified Data, or other anonymous data from Personal Data we collect, including Wellness Data, for our business purpose, including to analyze the effectiveness of the Services, to improve and add features to the Services, and to analyze the general behavior and characteristics of users of the Services. We also use anonymous Wellness Data for research purposes to help us and our research partners answer important questions about human performance and create an even-better experience for our members by identifying cutting-edge insights and providing new content and product features.

Direct marketing and advertising. We may use data from the Personal Data we collect, including Wellness Data and certain data collected when you browse our website, to send you direct offers marketing messages or advertise the Services or other GLUCOCARE product offerings.

  • Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. We and our advertising partners may use Cookies and similar technologies to collect information about your interaction over time across the web, our communications, and other online services, and may use that information to serve online ads. We comply with the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising. To learn more about the industry self-regulatory programs and other information and choices about interest-based ads, please see the section above entitled “Online tracking opt-outs.”

Compliance and protection, including to:

  • Protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services;

  • Comply with or enforce our legal or contractual obligations, resolve disputes, and enforce our Terms of Use and Terms of Sale;

  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;

  • Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); and

  • Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

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6. HOW WE SHARE PERSONAL DATA

We may share your Personal Data with:

  • Service providers, such as payment processors, vendors who advertise our Services or other GLUCOCARE products, security and fraud prevention consultants, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel, that provide services to us or on our behalf; our service providers also include our third-party Large Language Model (“LLM”) partner that powers GLUCOCARE;

  • Advertising partners that may collect information on our website through Cookies and other automated technologies, including for the interest-based advertising purposes described above. We do not share your Wellness Data with advertising partners;

  • Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us;

  • Authorities and others, including law enforcement, government authorities, and private parties we believe in good faith to be necessary or appropriate to comply with the law or legal process; and

  • Business transferees, such as acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, GLUCOCARE or our affiliates (including, in connection with a bankruptcy or similar proceedings).

  • Distributors and retailers of our Services or other GLUCOCARE products;

  • Affiliates of GLUCOCARE.

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7. HOW YOU MAY SHARE PERSONAL DATA THROUGH GLUCOCARE

Depending on your use of the Services, you may share Personal Data with:​

  • Third-party social media platforms, or linked accounts, devices, or features, when you choose to connect your account on those services with GLUCOCARE or post content to social media;

  • The Public. When you make Personal Data visible to other users of the Services, it may become publicly available and can be collected, viewed, and used by anyone;

  • Managing entities. If your use of the Services is on behalf of or managed by a managing entity, such as a coach, team, organizing body, or other entity with which you are affiliated, your account information and Personal Data may be shared with the managing entity subject to your consent, and you hereby consent to that managing entity allowing that information to be publicly shared, subject to any features of the Services that expressly override that control. The managing entity will determine how the relevant information and content is shared; and

  • Corporate wellness programs. If you use the Services in connection with an employer or organizational corporate wellness program, we may share your information with that organization subject to your consent. Typically, we will share only Aggregated Data with these organizations.

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8. THIRD-PARTY AI TECHNOLOGY

We require our LLM partner to use your anonymized GLUCOCARE metrics only for the purpose of allowing GLUCOCARE to generate health data results. We have ensured that our LLM partner has a “Zero-Retention/Zero Training Policy” with respect to your GLUCOCARE metrics, meaning that our LLM partner will not store or retain any of the anonymized GLUCOCARE metrics they receive through your use of GLUCOCARE, and our LLM partner will not use any of the anonymized GLUCOCARE metrics they receive for training any algorithms or LLM technology.

We will only share your anonymized GLUCOCARE metrics with our LLM partner.

GLUCOCARE may retain the history of your health results to ensure we have access to these results while providing health trends. 

If you agree to use GLUCOCARE, please note that Consistent with our Privacy Principles, GLUCOCARE employees will only access member Personal Data when required to provide services and support.

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9. YOUR CHOICES

Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request access to or a full deletion of your account and corresponding data by contacting support@glucocare.ai. You will be asked to complete a verification form in connection with such access or deletion request in order to ensure that you have the authority to access or delete your account. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you update or delete it.

Privacy settings. You can change certain privacy settings, such as whether you are searchable on GLUCOCARE by your name or username, if you scroll down to Settings, located on the Main Menu page of the GLUCOCARE mobile application, and select “Privacy,” where you can choose to make yourself private or searchable.

Push notifications and device permissions. Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request access to or a full deletion of your account and corresponding data by contacting support@glucocare.ai. You will be asked to complete a verification form in connection with such access or deletion request in order to ensure that you have the authority to access or delete your account. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you update or delete it.

Geolocation data. You may allow or disallow GLUCOCARE to collect geolocation data by enabling or disabling location services on your mobile device. If you decline to grant GLUCOCARE access to this data, we will not be able to provide certain Services, capabilities, or features to you.

Wellness Data. You can disable collection of additional Wellness Data by un-pairing your GLUCOCARE device from your mobile device.

We will only share your anonymized GLUCOCARE metrics with our LLM partner. If you no longer wish to use GLUCOCARE, you can simply not interact with the feature.

Marketing communications. We give you the ability to opt-out of marketing-related emails and other communications by contacting us at support@glucocare.ai. You cannot opt-out of receiving certain non-marketing emails regarding the Service.

Online tracking opt-outs. There are a number of ways you can opt-out of certain interest-based advertising and other online tracking activities, which we summarize in the “Online tracking opt-outs” section above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to online services. The Services do not currently support “Do Not Track” requests or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

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10. OTHER SITES AND SERVICES

The Services may contain links to websites and other online services operated by Third Parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any Third Party. We do not control mobile applications, websites or online services offered or operated by Third Parties, and we are not responsible for their actions. You can learn about and control how these Third Parties use and share Personal Data about you, including with GLUCOCARE, by reviewing their privacy notices and exercising the privacy choices the Third Party may offer.

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11. DATA SECURITY AND RETENTION OF PERSONAL DATA

We employ a number of physical, technical, organizational, and administrative security measures designed to protect the Personal Data we collect. While we endeavor to protect the privacy of your account and other Personal Data we hold in our records, no security measures are failsafe, and we cannot guarantee the security of your Personal Data.

We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.

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12. PERSONAL DATA OF CHILDREN

If you are under the age to consent to data sharing, as applicable based on your jurisdiction, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under the age to consent to data sharing, as applicable based on jurisdiction, we will delete that information as quickly as possible. If you believe that a child under the age to consent to data sharing, as applicable based on your jurisdiction,, may have provided us Personal Data, please contact us at support@glucocare.ai.

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13. CHANGES TO THIS PRIVACY POLICY

We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. We will alert you to changes by placing a notice on the GLUCOCARE website, by sending you an email, and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

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14. CONTACT US

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@glucocare.ai or at the mailing address below.

Gedung Bursa Efek Indonesia Tower 1, Level 3 U, Senayan, Kebayoran Baru, Jakarta Selatan

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