Table of Contents

Privacy Policy

1. What Information Do We Collect?
2. How Do We Use Your Information?
3. With Whom Do We Share Your Information?
4. How We Keep Your Information Secure
5. Right To Access And Correct
6. Update
7. Other Important Notices
8. Contact Information

Palette (“Palette”, “We”, “Us”, “Our”, “the Company”) values your privacy and is committed to protecting your Personal Information. We understand your personal information is important to you and we want you to know how we collect, use, share, and protect your information. This Privacy Policy tells you what information we collect from visitors of websites owned by Palette ("Websites") and users of hardware, mobile applications ("Apps") and services owned and controlled by Palette (collectively, “Products” and/or “Services”), how we use that information, how we may share that information, how we protect your information, and your choices regarding your Personal Information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat and safeguard your information. This Privacy Policy applies to hardware and software including website and mobile apps, and applies to residents of the United States. This Privacy Policy does not extend to websites operated by third parties or other offline sources, including websites we link to. Palette is therefore not liable for their privacy policies, procedures and practices.

This Privacy Policy may be updated at any time. When the Privacy Policy is changed, modified, and/or amended, the revised Privacy Policy will be posted on our website and mobile apps and the effective date will be noted. You accept any such modifications to this Privacy Policy by continued use of our products and services after such modifications are made; provided however, you have the right to refuse and reject such amendment for 30 days prior to its effectuation and terminate the agreement.

By accessing or using our Products and Services, you agree to this Privacy Policy. If you do not agree with the terms of this privacy, please do not use our Products and Services.

1. What Information Do We Collect?

We collect two categories of information from users: (1) Personal Information and (2) General Information.

“Personal Information” is information through which you can be personally identified, including any photographs or personal health information that you may upload. Personal Information that we collect may include:

• Contact information such as your full name, age, gender, location, email address, phone number
• Information to establish your Palette account including your photograph credit card and/or other payment information (if applicable) and your, serial number of the Palette hardware device you use
• Information used to provide Services such as certain health information, including weight, height, therapy aim (nominal value, target value, range, blood glucose value), therapy type (syringe or pump), type of diabetes, medical conditions, blood glucose level, amount of insulin, tablets, food intakes and nutrition, activities (duration / intensity), sleep data and mood, (temporary) basal rate (continuously administered insulin dose, units per time unit), medication, your healthcare providers’ contact, other therapy information
• Any other information or data that you provide when using our Products and Services including data you upload from your monitoring and treatment devices using our Apps or through third-party applications that connect to Palette Platform.
• Personal Information you voluntarily provide to us, including through registrations, order information, applications, surveys or other inquiries.

We do not collect information that would directly identify you by name unless you choose to provide it to us. You can choose not to provide us with certain information, but please be aware that may impact the Services provided to you.

“General Information” is information we obtain automatically from your connection, interaction with Palette Websites, Palette Apps and the use of Cookies and other technologies. General information does not identify you personally. General information we collect when you use our Website or Apps may include but is not limited to the domain and host from which you access the Internet, the Internet protocol address of the computer or smartphone you are using (“IP Address”), the browser software you are using, the operating system you are using, the date and time that you access our Websites or Apps, the specific pages or features you use, and the number of visits you make to our Websites or Apps.

“Cookies” are small pieces of information which the Websites or Apps store on your computer and can later retrieve to recognize your browser and track your use for marketing purposes. To learn more about cookies, visit http://www.allaboutcookies.org.

"Web Beacons" We also employ a software technology known as a pixel tag or Web beacon. A Web beacon is a line of code that we place on our Websites, Apps or e-mails which allows us to analyze our advertising and the general usage patterns of visitors to our Websites and users of our Apps. These help us better manage content on our site by informing us what content or promotions are effective. Unless you consent, we do not collect personally identifiable information from you through the use of web beacons. You may not disable Web beacons.

Other Indirect Collection

The Websites permits you to use a third party social networking platform such as Facebook, Pinterest, Twitter, and Google+. This includes use of social media plugins such as Facebook “Like”, Tweet, Pinterest “Pin,” Google “+1” buttons, etc. When you use these social networking platforms and plugins, your username and password for the available service or collected from you on these services may be shared with us. When you use social networking platforms and plugins, you share your information with them and their privacy policy applies disclosure of such information. In addition, they may be able to collect information about you, including your activity or may notify your connections on the social networking platform about your use of the Palette Websites. Such services may allow your activity to be monitored across multiple websites for purposes of delivering more targeted advertising. Please note that their own privacy polices apply and we encourage you to read them. We may add new social networking plugins and buttons to our Websites from time to time.

We may employ over time various different advertising or remarketing services that serve you targeted advertisements to make your online experience more focused to your interests. These services may place a remarketing pixel and/or on the Website in order to recognize your browser and serve advertisements that relate to prior searches and activities you participate in on the Website. We will not run interest-based advertising campaigns that collect Personal Information. We will not use or associate Personal Information with remarketing lists, cookies, data feeds or other anonymous identifiers. We will not use or associate targeting information, such as demographics or location, with any Personal Information collected from the ad or its landing page(s).

2. How Do We Use Your Information?

We may use your Personal Information to provide Products and Services to you, including the Apps and Websites, respond to your inquiries, provide information on Products and Services or have a representative contact you regarding our Products or Services, specifically, if you agree, by checking the appropriate box, to allow us to contact you. Unless you have otherwise opted out of receiving email communication from us, you agree by using our Products and Services, to allow us to use your email for customer communication and provision of Services consistent with this Privacy Policy, when the law permits us to do so. For example, if you have not logged into our App for a significant period of time, we may use your Personal Information to contact you to see if you need help with our App

If you are using a Palette hardware device (the Placemat) in connection with the Services, you understand and acknowledge that when you use your blood glucose monitor, insulin pump, continuous glucose monitor or physical tracking device (exercise, sleep, etc.) in connection with the Palette hardware device, readings from your monitor will be automatically uploaded to your account with us. These automatically collected readings are considered Personal Information for the purposes of this Privacy Policy. Further, when you seek support from us, you understand and acknowledge that the individual(s) providing you with support may need to access these readings in order to understand the problem you are seeking support for; in this case, this information will only be used to help provide you with support.

We may use your Personal Data along behavioral and tracking data to provide personalized care guidance using our machine learning technology. Our machine learning technology uses your historical data in conjunction with other aggregated data that we have collected from other users in order to provide you with personalized service. We do not share your Personal Data or any other data that is not de-identified or aggregated with other users of our Products and Services.

We may also use your Personal Information to update you on special offers related to our products or services, and to improve our Products and Services. Similarly, we may use your Personal Information to provide product announcements, information regarding health topics, or to deliver other information we believe you may consider informative or useful. Furthermore, we may also use your Personal Information in any other way that we may describe to you when you provide the information to us or to which you consent. We may occasionally contact you to gather customer service information to help us determine how we can improve our Products and Services to better meet your needs. Because we provide a service for the coordination or management to health, wellness and related services, we collect the sort of personal and medical information needed in order to provide such services. We may also de-identify and/or aggregate data about users of the Palette for various business, scientific or research purposes including product, service or program development and improvement.

You may be asked to participate in academic, clinical, commercial or other research studies, either by Palette or by entities performing research. You are under no obligation to participate in this research. If you do agree to participate, you may be asked to link your Palette account to the study coordination account, or to provide a unique identifier that will allow the researcher or institution to link other personally identifiable information to your Palette information. Only you can agree to this linkage with other information or databases. Palette will not link the information in your Palette account for academic, clinical, commercial or other research studies without your direction. If you agree to participate in a research study, the person or organization conducting the study may require you to sign a written consent to participate, which may include terms and conditions that are different from those of this Privacy Policy.

We may combine or cross-reference your Personal Information with other information we acquire about you directly or through third party sources, (such as: Apple, Google,…) to help customize the information, products or services we provide to you. By accepting this Privacy Policy, you allow us to combine and cross-reference your information.

Only those employees who need access to your Personal Information to fulfil their employment duties will have access to it.

We may use tools to collect information about use of our Products and Services, including but not limited to, Google Analytics or other similar services. Such tools collect information regarding how users use Palette Apps and websites, what information they view when they do so, and what other sites and/or apps they used prior to coming to Palette Apps and websites. We use the information we get from such tools only to improve our Products and Services, tailor content, deliver a better experience and manage our advertising. Google’s use of information it acquires about you or your use of Palette is governed by Google Analytics Terms of Use and the Google Privacy Policy.

We may also collect, aggregate and maintain anonymous information about the visitors to our Apps and Websites and share such aggregate information with advertisers, business partners, sponsors and other third parties.

With respect to the collection and use of General Information, you have the ability to disable or manage the use of cookies on your computer using controls in your browser. However, you are not able to opt out of the uses of General Information otherwise collected as set forth in this policy. Please note that certain features may not be available when cookies are disabled. Please see the Third Party Websites and Ad Services section below to learn more about opting out of certain advertisement services.

3. With Whom Do We Share Your Information?

Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not sell or rent your Personal Information to third parties or disclose any Personal Information we gather from you through our Apps and Websites to third parties.

Through our Provider Portal, we allow you to share your Personal Information with your clinicians to enable them to assist you with care management and care coordination. If you allow your clinician to access your data for care management, you agree that your clinician will have access to all of your Personal Information collected through our Apps and Websites.

From time to time, we may use third parties to provide products, services or otherwise support our business or collaborate with third parties with respect to development, promotion or other business activities related to a particular product or service. As a result, we may disclose Personal Information to contractors, service providers and other third parties but such disclosure will be limited to enabling those third parties to provide their products or services. To the extent a third party’s Privacy Policy separately governs their use of your data obtained via Palette, you will be notified and given an opportunity to review such terms. We may also disclose Personal Information to our subsidiaries and affiliates.

In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of Palette, in whole or in part, your information may be transferred as part of the transaction, including during the due diligence process, as long as, the party acquiring such information agrees to be bound by the terms of this Privacy Policy.

We may also release your Personal Information to third parties as required by law, when we believe disclosure is necessary to comply with a legal or regulatory requirement, judicial proceeding, court order or legal process served on us, to protect the safety, rights or property of patients, customers, the public or Palette or defend Palette and its officers, directors, employees, attorneys, agents, contractors and partners, in connection with any legal action, claim, or dispute.

4. How We Keep Your Information Secure

Your Personal Information is stored on servers hosted in the United States. We may add a server location in other regions depending upon business need. Therefore, local tribunal and legislation will have jurisdiction with regards to the access to your Personal Information.

We seek to safeguard the security of your Personal Information and have implemented reasonable security measures consistent with applicable laws, safe harbors, and accepted practices in the healthcare industry to protect the confidentiality of your Personal Information. We have put in place a variety of information security measures to protect your Personal Information, including encryption technology, to protect your Personal Information during data transport and at rest. You will know that a page on our Websites is encrypted where you see the SSL symbol or the URL begins with HTTPS. General pages of our Website may not be encrypted, including pages that allow you to contact us via email. We limit the access to your Personal Information to employees who needs it for the execution of their duties.

Despite our efforts, however, we cannot guarantee the absolute security of your Personal Information, nor can we guarantee that information that you provide will not be intercepted while being transmitted to us over the Internet. There is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your Personal Information over the Internet will be intercepted. Therefore, we urge you to also take every precaution to protect your Personal Information when you are on the Internet or using our Apps and Websites. In order to protect your privacy, you need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately, never share your sign-in name or password and always log out of the Apps and Websites when you are finished using the service.

When you use post on a Palette forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

We will store and maintain your information in accordance with this Privacy Policy and as required to provide you Products and Services through the Apps and Websites. We will also retain your information for as long as your account is active or as needed to provide you Products and Services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

5. Right To Access And Correct

On written request and subject to proof of identity, you may consult the Personal Information that we have collected, and ask that any necessary corrections be made, where applicable, as authorized or required by law. These categories may change as our Products and Services change. Any General information that is automatically collected cannot be later changed or updated. Certain information is required to access some of our Services, so your deletion of certain information, or provision of inaccurate information, may render the Services inoperable, in whole or in part. When you update information, however, we often maintain a copy of the unrevised information in our private records. Please note that we may use aggregate data derived from your information after you have requested it be modified or deleted, but not in a manner that would identify you personally.

However, to make sure that the Personal Information we maintain about you is accurate and up to date, please inform us immediately of any change in your Personal Information with the contact information at the bottom of this Privacy Policy.

You may opt-out of most communications from us. Please note that if you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes. Please note that if you subsequently opt out of any communications from us, you will not receive a recall notice. You acknowledge that certain communications between you and Palette are required to provide you the Services and maintain your account.

6. Update

Our Privacy Policy may be periodically amended without notice to reflect changes made to our practices. We therefore invite you to consult our Apps and Websites from time to time to stay informed of the latest developments. Continued use of our App and/or Services after the effective date will be construed as an acceptance of these amendments on your part. The date of the last update is the one that appears at the top of this Privacy Policy.

7. Other Important Notices

Children’s Privacy: We are committed to protecting the privacy of children. As such, we do not intentionally collect data from users under the age of 13 years old in connection with our general purpose Apps or Websites or Services. We recognize that some users of our Apps and Services specifically intended for use with children may be parents or guardians utilizing our services to help manage their child’s health. As such, all parents or guardians are notified directly before information on their children is collected. Before any information for a child is collected or used, we obtain parental (or legal guardian) consent. Any data collected from persons under the age of 13 years of age will be used, collected, and protected, in accordance with this Privacy Policy. Parents may review their children’s information, request that it be deleted and prohibit any further data collection following the same procedures outlined below for adults. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If you have any questions regarding how data collected from children is handled, please contact us with the contact information at the bottom of this Privacy Policy.

Third Party Websites and Ad Services: Please be aware that our App and Websites may have links to third-party websites that may collect Personal Information about you. When you click on one of these third-party links, you are entering another website. We do not have control over any third party website and this Privacy Policy does not cover the information practices or policies of such thirdparty websites. We encourage you to read the privacy policies of all such websites since their privacy policies may be materially different than our Privacy Policy.

In addition, some advertisements on our Apps and Websites are served by third-party advertisers, ad networks, ad servers and/or via Google. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about our users. This may include information about users' behavior on this App and other websites to serve them interested-based (behavioral) advertising. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement, we recommend that you contact the responsible advertiser directly.

Email communications: Do not send email communications containing personal health information to us. We cannot secure any Personal Information sent by email because such information can be accessed by other internet users. If you send us a question by email, our use and disclosure of that information will be limited to the minimum necessary to respond to your question.

Email and Text Message Communications: You may receive emails or text messages from us regarding your use of Palette if your computer or cellular device supports this type of program. If you do not want to receive email, text messages, or other mail from us, please contact us at legal@aeglepalette.com or simply opt-out from each message type. Please note that if you have opted out of receiving email or other messages from us, we may still need to contact you via email, but only with regard to the status of your account (for example, to notify you when your subscription is about to expire); you cannot opt-out of these emails, unless you cancel your account entirely.

De-Identified Information: On occasion, we may make arrangements with certain customers or business partners to share certain de-identified aggregate pattern information in order to assist such customers or business partners to improve their service (such as evaluating patterns, utilization, usage and trends). We may also share such information with you or other users of our service. This type of information may be based in part on information related to you, but does not allow for the personal identification of any individual (in other words, it is “de-identified”). This information will not be used by the customer or business partner for marketing and/or any purpose other than as set forth above.

We remove your identity from your Personal Information (contact, health and/or financial) and may work with it as anonymous (“de-identified”) information. De-identified individual information is information about a user presented in a form where information about one anonymous user would be indistinguishable from information relating to other anonymous users. De-identified individual information is not in a form that allows anyone studying the information to personally identify any user.

Aggregate information is information that describes the habits, usage patterns and/or demographics of users as a group but does not reveal the identity of particular users. Your anonymous data is combined with the anonymous data of other users and becomes statistics. We may use aggregate information to understand the needs of our user community and determine what kinds of programs and services we can offer to you. We could use this anonymous information to give potential users or business partners a picture of our community and services. Aggregate information may be provided or sold to third parties. Absolutely no personal identifying information is included in the aggregate reports; each individual remains anonymous.

Locator information is your name, electronic messaging address, physical address, and/or other data that enables someone to personally identify you. We may use Locator information as is necessary to enforce any of the terms of this Privacy Policy.

Grant Healthcare Providers, Care Team and Researchers Access: You can grant access to your Palette account to healthcare professionals and care term including family, friends, or anyone else. Healthcare providers and care team to whom you provide access will be able to view and comment on the health and other information in your account. Only if you grant them permission will they be able to upload information to your account or, if applicable, edit information in your account.

A healthcare provider, such as your doctor or other healthcare professionals, or a researcher conducting a study in which you participate, may establish a professional account to store information about you in Palette. That healthcare provider and researcher may invite you to open a Palette account. If you accept that invitation, you will become a user and will have control of all the information associated with that account, which will be your Palette account. When you open the account, the clinician or researcher who invited you to open the account will automatically be a member of your care team. You may remove the clinician or researcher from your care team by sending an email to or write us at the address below.

Professional Account for Healthcare Providers, Care Team, Researchers and a Sponsor: To register a professional account as healthcare providers, a care team, researchers or sponsors, you must provide an email address and create a password. You use the email address and password to log in. We may also collect contact information, such as your name, address, phone number, and certain non-personal information that does not itself identify you, such as your IP address. We may use this information to: deliver, administer and improve Products and Services; provide customer service; improve and personalize your experience; better understand needs and interests; fulfill requests; deliver special announcements and updates about Palette; and contact them about any of the above as well as any changes to or notifications regarding your account. We may also collect other information you provide to us, such as information or comments about a user. We use the information you provide as a professional to display notes, comments and other features of Palette. A user owns all content you generate on that user’s accounts and you have no control over that information, except in the course of editing comments you have made. However, you can delete or change your personal information. You can also cancel your account at any time. Upon cancellation, we will delete your account information but not information or comments you have added to any user accounts. You can choose to stop receiving marketing or informational emails from us by clicking the “unsubscribe” link at the bottom of any such email.

If Palette will be acting as your business associate under the federal Privacy and Security Rules issued under the Health Information Portability and Accountability Act (“HIPAA”), our obligations regarding the privacy and security of the personal information you store in Palette will be governed by a separate written business associate agreement between us. Palette will not be subject to any business associate agreement unless it is executed on Palette’s behalf by an authorized person.

Law Enforcement and Protection of Users and the Site: To the extent permitted by law, we may disclose Personal Information to governmental authorities or third parties pursuant to a legal request, subpoena or other legal process. We may also use or disclose your Personal Information as permitted by law to apply or enforce this Privacy Policy, or protect our rights, interest, or property as well as those of our affiliates, customers, or Palette users. Following such disclosure to any third party, your Personal Information may be accessible by others to the extent permitted or required by applicable law.

Your California Privacy Rights

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to or write us at the address below.

Make sure to state that you are a California Resident.

Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in their web browsers. While the United States Federal Trade Commission has endorsed DNT, our Website does not support DNT codes. However, except in the case of analytics cookies, remarketing and other features of Google Display Advertising described above, our Website limits tracking to the internal uses described above. Except in the case of analytics cookies, remarketing and other features of Google Display Advertising described above, our Website does not track your use across multiple websites, however, other websites to which we link may. Please review their privacy policies to understand how you may be tracked.

8. Contact Information

Please send any comment, question or complaint regarding our Privacy Policy or any request to access or correct your Personal Information or request alternative communication methods by mail or email using the following contact information. You may also send written requests to rescind your consent to our use of your information to the below contact information:

AEGLE Palette
Legal Department
13809 W 56th Ter, Shawnee, KS 66216
legal@aeglepalette.com