Last updated: 02/2025
LifeScan's vision is to create a world without limits for people with diabetes and related conditions by advancing glucose management and diabetes care with pioneering technologies and new products defined by simplicity, accuracy and trust. Your privacy is very important to us. In this Notice, we may refer to ourselves as "we," "us," or "our," by which we mean LifeScan Global Corporation and its subsidiaries. We use the word "you" throughout this Notice to refer to anyone within the scope of this Notice. The controller of your data is LifeScan Global Corporation.
This Notice discusses:
This Notice describes how we collect, use, protect, and process Personal Data we collect from or about you when you visit websites or use mobile apps operated and controlled by LifeScan, use our OneTouch® brand of products and solutions (including their websites and mobile apps), communicate with us, or otherwise interact with us in your capacity as a consumer. This Notice does not apply to employees or job applicants of LifeScan, or its subsidiaries. LifeScan has a number of websites and brands that it operates, including the OneTouch® brand of products and solutions, and this Notice also applies to information collected by those brands and through those websites and mobile apps. Throughout this Notice, we use the term "Services" to describe our product and services offerings, including our websites, mobile apps, OneTouch Reveal® products, OneTouch® Solutions offerings, and any other products or services offered by us.
This Notice explains how LifeScan may use and disclose information we collect from and about you, as well as your ability to control certain uses of it. By visiting our websites, interacting with us, or providing us with your data, you consent to the collection, use, and disclosure of your Personal Data in accordance with the terms of this Notice. If local laws in your country require that we process your Personal Data in a different way, we will comply with those local laws. Please read this entire Notice before using any of the LifeScan Services.
If your organisation has a separate contract or agreement regarding LifeScan's use and processing of Personal Data, to the extent that agreement conflicts with this Notice, the agreement will apply. However, where this Notice provides additional rights to individuals beyond the rights included in any such agreement, we will also afford individuals with the rights and choices they may have under this Notice.
The purpose of this privacy policy is to:
For all data controllers, it contributes to the fair processing of data, and helps build a relationship based on trust with all our company's stakeholders.
This Privacy Policy does not apply to employees or applicants for employment at LifeScan or its subsidiaries.
For each type of processing of your personal data that we carry out, we rely on an appropriate legal basis, which may include:
Your consent: In some cases, we will explicitly ask for your consent to process your personal data, for example, for certain direct marketing communications.
Performance of a contract: When you use our services, we process your personal data to fulfil our contractual obligations to you.
Legal obligations: We may be required to process your data to comply with a legal obligation, such as keeping invoices for tax purposes.
Legitimate interests: In some cases, we process your data to pursue our legitimate interests in a way that could reasonably be expected in the course of running our business and which does not affect your rights and freedoms in a significant way.
We undertake the collection of strictly necessary data only, to achieve the aforementioned purposes and do not use them for any other purposes without prior consent.
We collect personal data directly from data subjects (name, e-mail address, etc.) as well as indirectly through the use of our different platforms (browsing data, cookies, etc.). Each type of data collected will be clearly identified in our collection process.
The term "Personal Data" in this Notice means any information which could identify you as an individual, either directly (for example, your name) or indirectly (such as an IP address or other unique identifier), or any information that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
LifeScan may collect and process the following categories and types of Personal Data when you use the Services:
When you are asked to provide your Personal Data, you may have an option to choose not to provide it. While this is your choice, if you do not provide it, it may inhibit our ability to provide some elements of the Services to you.
If you are providing information of someone other than yourself (for example, if you are a caregiver, parent or guardian or a healthcare professional providing a patient's information) then you are confirming to us that you have any legally required authorisation, consent or other lawful authority to share the other person's information and for us to use it in accordance with this Notice.
In addition to the above information, if you are a healthcare professional, LifeScan may collect:
Non-Personal Data
We may collect and use information that is not personally identifiable, such as information that is aggregated, de-identified, or otherwise not personal in nature. We may also take Personal Data we have collected and de-identify it or compile it so that it is aggregated and no longer personally identifiable in nature.
When you are asked to provide your Personal Data, you may, as an exception, choose not to provide them. It is important to note that certain data is essential to enable us to provide you with our Services. If you choose not to provide this mandatory data, it may limit our ability to offer you some of our Services.
The data collected is used to provide and improve our services, to communicate with users, to personalise the user experience and to comply with our legal obligations.
The information we collect from or about you and how we use it depends on your interaction with us. For example, we collect different information from you when you use our Services, contact us for information, visit our websites or use our mobile apps.
Information Directly Collected
LifeScan collects Personal Data directly from you or that you provide to us in a number of ways, including:
Information Automatically Collected
LifeScan collects Personal Data automatically, including:
Information from Third Parties and Other Sources
LifeScan collects Personal Data from third parties and other sources, including:
Combining Information
We may combine Personal Data we collect from or about you with Personal Data or information we collect from other sources, for example social media or from public sources.
Our legal basis for processing your Personal Data depends on the reason for which we are processing it. Our legal bases for processing your Personal Data generally include processing with your consent, to perform our contractual obligations to you and to provide you with the Services you request from us, to comply with our legal obligations, and processing that is necessary in our legitimate interests.
We process your health information when you use the Services on the basis of your explicit consent.
We use your Personal Data for the following purposes where it is necessary for us to perform our contractual obligations to you and to provide you with the Services you request from us:
We use your Personal Data for the purposes listed below where it is necessary or in our legitimate interests, unless you have opted in to receive communications where an opt-in is required by law (as applicable to the purposes listed below). If you have opted in to receive such communications, our additional legal basis for processing your Personal Data for this purpose is your consent.
We use your Personal Data for the following purposes in order to comply with a legal obligation that we are subject to, or where necessary to establish, exercise or defend legal claims:
We may also use your Personal Data in other ways, with your consent.
We may permanently anonymise or de-identify your Personal Data so that it is no longer Personal Data under relevant laws. After permanent anonymisation or de-identification, you can never be identified and the data is not traceable to you, and we will not take steps to re-identify the data so that it is identifiable. We may use or share such anonymised or de-identified data for statistical analysis, clinical research, product development or improvement, demographic analysis or other similar activities. The legal basis for such data processing is our legitimate interest. We may export and process permanently anonymised data in any country in which we or one of our service providers or business partners has operations. We may combine or aggregate anonymised or de-identified data with other third-party data that we collect.
We may disclose any or all categories of Personal Data that we collect from or about you when you use the Services or otherwise interact with us with any of the following categories of third parties:
In addition, we may use and disclose information collected through our Services as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect the operations of LifeScan group companies; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
The Services may include functionality that links to or integrations with the products, services, websites or apps of our business partners ("Partner Apps"). In the event that you use Services that include such functionality, our business partners' privacy policies, notices, or statements will govern how they handle your Personal Data in connection with such Partner Apps, while this Notice will continue to govern how we handle your Personal Data. We are not responsible for our business partners' privacy practices, and you should review the applicable Partner App privacy policies before using such functionality.
We may send you email messages promoting our Services or other information about our programs and offers; and, where required by law, when we have the appropriate consent to do so. You may opt out of receiving marketing and promotional communications at any time by contacting us, using the unsubscribe link in the applicable communication, or by changing your preferences in the "My Account" or "Settings" function, if applicable. If you opt out of receiving marketing and promotional communications from us, you may continue to receive legal notices, non-marketing product updates (such as, updates to our terms of service or use that govern the product), and other transaction-related messages from us.
If you are a healthcare professional and no longer wish to receive communications from the LifeScan Diabetes Institute, you can update your preferences in your member profile at https://www.lifescandiabetesinstitute.com or by unsubscribing, here.
We use persistent identifiers such as cookies, clear GIFs, pixel tags, web beacons, and similar technologies to automatically collect data from you when you use our Services. These persistent identifiers collect information that allows us to authenticate you to the Services, to analyse how the Services are used, to link information about how you use the Services with your account, to analyse the effectiveness of our messaging, and to help to tailor our products, the Services, and our communications to you. We may also use persistent identifiers to identify you across other media, websites, or apps, or through your use of our other products or the Services to help to tailor our offerings and to provide enhanced personalisation and communications. When we use the term "cookies," we intend for this to encompass cookies, clear GIFs, pixel tags, web beacons, and similar technologies. For more information about how we use cookies to automatically collect information from you and how you can manage your preferences or exercise rights you may have regarding information collection through cookies, please review our Cookie Policy.
Cookie Preferences and Choices
We appreciate that you may wish to express certain preferences with respect to some or all categories of cookies used to collect information, including Personal Data, from you, through our websites and applications. You may express your preferences regarding our collection of information via cookies through:
LifeScan does not sell Personal Data for money, but in the last 12 months we have shared Personal Data including identifiers, commercial information, online identifiers and internet or similar network activity details, with providers of advertising and analytics services, network advertisers, partners who assist us with target audience creation, retail partners, and brands of our parent company. This sharing and disclosure may be considered a "sale" or "sharing" under applicable state law.
If you would like to update or correct your Personal Data, you may do so by updating your information in the "My Account" or "Settings" feature of the Services.
In addition to the foregoing, depending on the jurisdiction in which you reside, you may have the following additional rights and choices regarding your Personal Data. While we use the term Personal Data throughout this Notice, we intend for this to include "personal information" where that is the term used under applicable law. If you have questions about whether you live in a jurisdiction that affords privacy rights, please contact us using one of the methods listed below.
Right to Request Access or Right to Know
Where required under applicable law, you have the right to request that we disclose information to you about our collection and use of your Personal Data over the past 12 months. You have the right to request the following:
Once we receive and confirm your verifiable consumer request, we will provide you with the information you request unless an applicable exception applies.
Right to Portability
Where required by applicable law, after you make a request to access or know your Personal Data you may have the right to request to obtain a copy of this information in a portable, readily usable format that allows you to transmit the information to another party, to the extent it is technically feasible. You may also have the right to request that we transfer your data to another organisation, under certain circumstances.
Right to Deletion or Right to Erasure
You have the right to request that we delete any of the Personal Data that we collect or retain about you, subject to certain exceptions. After we receive and verify your request, we will delete (and direct any of our service providers that hold your Personal Data on our behalf to delete) your Personal Data from our records, unless an exception applies. We may deny your deletion request if retaining your Personal Data is necessary for us or our service providers, as permitted by law.
Right to Opt Out of the Sale or Sharing of Personal Data, or the Use of Personal Data for Targeted Advertising
You have the right to opt out of the sale or sharing of your Personal Data. Information about our practices that may constitute a "sale" or "sharing" of your Personal Data as defined by law are noted in the above section titled "Sales or Sharing of Personal Data." You may exercise your right to opt out by following the instructions set forth in this section of this Notice titled "Exercising Your Rights," or by utilising the "Do Not Sell or Share My Personal Data" button on our website. Please note you may also need to update your preferences in the cookie consent tool on our websites and apps in order to fully opt out.
In some states, this right is known as the right to opt out of the use of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of certain decisions.
Right to Limit Certain Uses and Disclosures of your "Sensitive Personal Data"
You have the right to limit our use and disclosure of your "Sensitive Personal Data," as that term is defined in applicable statutes, where we have collected it to use as necessary to perform the services or provide the goods reasonably expected by you, and as otherwise authorised by the statute and regulations. We use your Sensitive Personal Data in ways that you would reasonably expect are necessary to perform the services or to provide you with the Services you request. We may also use your Sensitive Personal Data for our legitimate business purposes, including for marketing to you. For details on how we use your Sensitive Personal Data, and your right to opt out of certain uses, please review the information above.
Right to Correct Personal Data if the Data is Inaccurate
If you believe or discover that Personal Data we have collected about you is inaccurate, you may contact us to request that we correct and update the information so that it is accurate. Where applicable, you may also log into the "My Account" or "Settings" page of the Services to update your information.
Right to Withdraw Consent
If you have previously consented to the use of your Personal Data for direct marketing or targeted marketing, you may withdraw your consent at any time.
Right to Restrict or Object to Processing
You may have the right to restrict certain processing of your Personal Data, or to object to certain processing of your Personal Data, including where our legal basis for the processing is your consent, where the processing involves Special Category Personal Data or Sensitive Personal Data, or where it involves automated decision making technologies. This right is subject to certain restrictions.
Right to Appeal
If you are a resident of certain jurisdictions, you have the right to file an appeal with us if we deny your request to exercise your rights. Requests to appeal can be communicated through the same means by which your request was submitted. If we deny your appeal, you may have the right to appeal to your state regulator. We will provide you the information of the applicable regulator if we deny your appeal.
In addition to the above rights, you also have the right to:
Right to Freeze the Use of Your Data
If you dispute the accuracy of the data used, you can ask us to freeze the use of your data. During this time, we will keep your data but will not use it.
Right to Delist Content
The right to delist allows you to ask us to remove certain search results associated with your identity, so that you are no longer associated with content that would be prejudicial to you.
Right to Lodge a Complaint
You may have the right to make a complaint with the supervisory authority for your country of residence. If you are an EU Resident, details can be found here.
Exercising Your Rights
If you believe you reside in a jurisdiction that affords broad consumer privacy rights to its residents and you wish to exercise any of the rights described above, please submit a request to us by one of the methods noted at the end of this Privacy Policy.
Only you, or someone legally authorised to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.
Where this right exists under applicable law, you may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We will take steps to verify your consumer request, including that you are the person making the request, or you have authority to make the request on behalf of the individual the request relates to. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format: We endeavor to respond to verifiable consumer requests within forty-five (45) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination: We will not discriminate against you for exercising any rights you have under applicable law. Unless permitted by applicable law, we will not:
However, we may offer you certain financial incentives permitted by state law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Data's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
We retain your Personal Data for the period necessary to fulfil the purpose(s) for which it was collected as outlined in this Notice, unless a longer retention period is required or allowed by law or is needed in order to fulfil a legal requirement to which LifeScan is subject.
LifeScan uses various technical, organisational and administrative measures to protect your Personal Data against loss, unauthorised use or access. For example, when we transmit your health-related Personal Data, through our Services we use encryption technology. When our Services communicate with our analytics providers, encryption is also used. However, you should be aware that no data storage or method of transmission can be guaranteed to be 100% secure or error-free.
In order to ensure the safety of medical devices, regulators place a legal obligation on manufacturers to report certain complaints and potential adverse events to them. LifeScan may share this information with other LifeScan companies in other countries, its service providers or business partners who assist in the maintenance and operation of LifeScan's complaints database.
In some cases, LifeScan may not be the legal manufacturer of the devices that we promote or make available (continuous glucose monitoring system ("CGM"), for example). In those circumstances, we are obliged to pass on details of complaints and potential adverse events to the device's legal manufacturer so that they may report the matter to applicable regional or national regulatory bodies, including those that may have different data protection laws than the laws that apply in your country. This means that LifeScan may need to transfer details of complaints and potential adverse events relating to CGM outside the country in which you reside, which may include the United States. Where this occurs, LifeScan takes steps to ensure that your personal data continues to be treated in accordance with applicable data protection laws.
Where relevant, LifeScan enters into European Union standard contractual clauses (or equivalent measures) with the party outside the European Economic Area receiving the personal data. A copy of the relevant standard contractual clauses is available upon request.
LifeScan processes complaint and adverse event data in order to comply with legal requirements to which it or its business partners are subject. Where LifeScan processes health data (which is a special category of data or "sensitive personal information," as the term is used under the laws of some jurisdictions) for these purposes, LifeScan does so for reasons of public interest in ensuring high standards of quality and safety of medical devices. We may use data provided for complaint and/or adverse event reporting purposes for direct marketing where permitted by law.
If you are a healthcare professional, LifeScan may be required, by law or industry codes of practice, to report on or to make public disclosures of certain payments or transfers of value to healthcare professionals (such as consulting fees, travel and other permitted expenses). Where required by local law, we will disclose your identity, your location and the nature and amount of the transfer of value or payment.
The data we collect is stored on servers that guarantee a high level of security.
When we provide a link to another website or application that is not owned or controlled by LifeScan, your data is no longer within the scope of this Notice, and is subject to the information processing practices of that website or application. We may endeavor to provide you with notice when you are leaving our websites to that you are aware that you are leaving our website. However, we are not responsible for how such websites or applications handle your Personal Data. We urge you to read the linked website's privacy policy, notice, or statement. The inclusion of a link to a third-party website or application does not mean that LifeScan endorses that website or application.
As a global company, we have operations and service providers that may not be located in your country of residence. By using any of our Services or, where required by law, by providing us with your consent, your information may be processed and/or stored outside of your country of residence. Data protection laws in those countries may differ from the laws in your country of residence.
For residents of the European Economic Area ("EEA") some countries outside the EEA are recognised by the European Commission as providing an adequate level of data protection (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we endeavor to ensure that adequate measures are in place, including by ensuring that the recipient is bound by the European Union's Standard Contractual Clauses or by another method which has been approved by the European Commission, or by an applicable transfer framework approved by UK and/or Swiss regulators, as applicable.
We do not collect knowingly information through our websites or mobile apps directly from children under the age of 13. Some of the Services allow the creation of a parent or guardian account which allows for the submission of a child's Personal Data by a parent or guardian. Please contact us if you believe that a child has provided his or her Personal Data to us directly, without the consent of a parent and take appropriate steps to remove it or obtain consent, as permitted by law.
For privacy-related enquiries or complaints, please contact us as follows:
We may update this Notice from time to time. To the extent permitted by applicable law, any changes will be effective when we post the revised Notice on our Services and your continued use of the relevant Service after these changes means that you accept the relevant changes. If the changes are significant, we may provide a more prominent notice to let you know what the changes are (e.g. via our website or by email). This Notice was last updated as of the "Last Updated" date shown at the top of this Notice.