DEXCOM PRIVACY POLICY


THIS DEXCOM PRIVACY POLICY IS EFFECTIVE AS OF SEPTEMBER 14, 2015 AND REPLACES THE PRIOR DEXCOM PRIVACY POLICIES.

This Privacy Policy of DexCom, Inc. (“Dexcom”) applies to the Dexcom website located at http://www.dexcom.com/ and the webpages and other web addresses accessible from such site, including without limitation, DexCom Store (collectively, the “Website”); the software applications we make available for download at the Website, the Apple® App Store, other cell phone service provider locations or other locations we indicate or that may be accessed through computers or mobile devices (“Software Apps”); Dexcom Products (“Products”) and our data services available through the internet made available to users of Dexcom Products or Software Apps that provide and permit the access, collection, storage, processing, analysis and/or transmission of data generated by a DexCom Product or Software App (“Data Services”);  as well as any HTML-formatted email messages that we send to you that link to this Privacy Policy (collectively, including the Website, the Software Apps, the Products, the Data Services, and the e-mail, the “Products and Services”).

We refer to each user of our Products and Services as “you” or as a “User.”  Certain Dexcom Products require a prescription, and such Dexcom Products may only be used by the person for whom the prescription was issued (that person is referred to as the “Prescription Device User”). This Privacy Policy is subject to the Dexcom Terms of Use.  Capitalized terms not otherwise defined in this Privacy Policy shall have the meaning ascribed to such terms in the Dexcom Terms of Use.  By using any Dexcom Product or Service, you agree with the terms of this Privacy Policy.

Information We Receive

The information we receive about you (which we refer to collectively as your “Personal Information”) includes Registration Information, Feedback Information, Data Services Information, Use Information and Derived Information:

  • “Registration Information” is information you are required to provide in order to register with us when you register with Dexcom in connection with your use of a Dexcom Product or Service. This information may include your name, address, telephone number, email and other contact information, as well as information regarding your use of Dexcom Products and Services, including the serial number for your User Device.
  • “Feedback Information” is information you submit to us in connection with your use of Dexcom Products and Services, whether through our Website, through our Data Services, or otherwise, regarding Dexcom Products and Services, or other matters relating to us and our business, including the metadata relating to that information.
  • “Data Services Information” is information we receive and transmit through our Products and Services, including: 
    • Glucose readings;
    • Information associated with each glucose reading, including date, time, and device identifier;
    • Thresholds input into Data Services or Software Apps and notifications arising from those thresholds;
    • Any of the data generated or used by your Dexcom Products to produce other Data Services Information or otherwise available to us through your Dexcom Products, such as data used for technical support;
    • Information provided by you or about you by another person you have designated to receive any of your Personal Information through functionality of a Dexcom Product or Service (we call each such person a “Designated Recipient”).
  • “Use Information” includes:
    • Information we receive from the computer, mobile phone or other device you use in connection with Dexcom Products and Services, and information we receive from those Products and Services regarding your use, which may include your IP address and other information regarding your computer, your internet service, the browser you use, and your activities while using Dexcom Products and Services, such as how often you open Software Apps, your settings and other activity regarding your use of the components of Dexcom Products and Services; 
    • Information we receive from you in connection with our request for comments or feedback on third parties;
    • Information we may receive from advertisers and other third parties when you click on advertisements or links to third party websites while using Dexcom Products and Services, including the pages you visit, your activity on those pages and your purchases or other transactions with those third parties.
  • “Derived Information” is information that we create by combining and/or analyzing some or all of your Personal Information.

If any of the Personal Information described above does not reveal your specific identity or relate directly to an individual, we may use such “Other Information” for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

Your Rights and Responsibilities

  • You may update your Registration Information at any time by logging into your account on our Website, and you agree to keep your Registration Information current at all times while your account is active.
  • If you would like to review, correct, update, suppress, or delete Personal Information that you have provided to us, you may update such information maintained in your User Account on our Website or contact us at privacy@dexcom.com.  In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
    • You must comply with the terms of the Agreement.
    • You must only use your User Device as permitted by the Dexcom Product Labeling.
    • If you submit any Personal Information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

What We Do With the Information We Receive

  • Registration Information: We use Registration Information to manage your account and Dexcom Products and Services applicable to you, and as otherwise described below. We also use your email address to contact you regarding your account. We do not make any Registration Information public. We will use your User Account and Registration Information to link your use of Dexcom Services and Software Apps with your use of Dexcom Products, and it may be accessible by our personnel providing Dexcom Services.
  • Feedback Information: Feedback Information may be used by us and provided by us to our customers and third parties, in the form you provide as well as in excerpted, aggregated and anonymized forms, with or without attribution to you as the source. We may also use Feedback Information in our advertising, marketing and other communications with the public and in our business relationships, as well as in our internal communications, in each case with or without attribution to you as the source.
  • Data Services Information: We collect Data Services Information and store it on our servers, process it using Data Services, and transmit it to the User and each Designated Recipient, where applicable. We may use Data Services Information in connection with our provision of Data Services and for our operations, administration and product development, maintenance and support. We may remove information that identifies you from Data Services Information, and we may use such de-identified data for our business purposes as we determine, such as research and development, product improvements, business operations and process improvements, marketing purposes, including disclosing such de-identified data to third parties for their use as we determine.
  • Use Information: We collect Use Information and store it on our servers, process it using our systems, and analyze it for our business purposes. We do not disclose to third parties any Use Information that can identify you (except as permitted in this Privacy Policy), but we may remove information that identifies you from Use Information, and we may provide such de-identified Use Information to third parties as we determine for their use. 
  • Derived Information: We may use Derived Information to determine information, including Solicitations (defined in the next section), to be sent to you, the public or to targeted groups, and for our business purposes in accordance with the applicable provisions of this Privacy Policy.
  • Personal Information and Solicitations: As permitted by applicable law, we may use Personal Information of you and your Designated Recipients, if applicable, to determine which emails and notices we send to you and your Designated Recipients, if applicable, including emails and notices regarding opportunities relating to our Products and Services (we refer to these emails as “Solicitations”). You may opt out of Solicitations by contacting us by email at CustomerVoice@dexcom.com or by mail at the address listed in the “Contact Us” section below, and you may opt in again through one of those contacts.  We will try to comply with your request as soon as reasonably practicable.  Please keep in mind that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.As permitted by applicable law, we may share your email address or other Registration Information with third parties with which we contract for the purpose of providing you with Solicitations we think may be of interest to you.  You may opt out of our sharing of your information with third parties for these purposes by contacting us by email at CustomerVoice@dexcom.com or by mail at the address listed in the “Contact Us” section below.
  • Personal Information and Your Dexcom Experience: We may use Personal Information belonging to you and your Designated Recipients, if applicable, to tailor to you and your Designated Recipients, if applicable, the experience when using Dexcom Products or Services and the content viewed when using Dexcom Products or Services. We may use Personal Information to manage our Products and Services, including the Website, to improve our business and provide new website and product and service features, and to otherwise manage our business, but without disclosing your Registration Information except as necessary for such purposes.
  • Other Third Parties: In the ordinary course of our business, we will share Personal Information with companies we hire to perform services or functions on our behalf. We will not authorize those third parties to keep, use or disclose your Personal Information except for providing the services we have asked them to provide.We may provide your Personal Information to another company in conjunction with a corporate sale, merger, acquisition or dissolution involving Dexcom.
  • Law Enforcement and Legal Proceedings: We will use and disclose Personal Information as we are required to do by applicable law, including laws outside your country of residence, and may disclose Personal Information when requested by law enforcement authorities or regulatory agencies, including public and government authorities outside your country of residence, or when we determine that such disclosure is appropriate under the circumstances. We may use and disclose Personal Information to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; to protect our operations or those of any of our affiliates; to enforce this Privacy Policy; and to allow us to pursue available remedies or limit the damages that we may sustain.
  • De-Identification: We may “de-identify” your Personal Information by removing information that could identify you, and we may use such de-identified information for any purpose, except where we are required to do otherwise under applicable law.
  • Other Uses: We may use your Personal Information for purposes other than those permitted in this Privacy Policy but only after you consent to such use.

What Happens to Information You Share With Others

  • We have no control over Designated Recipients, and once a Designated Recipient receives your Data Services Information, even though the Agreement restricts the use of Data Services Information, the Designated Recipient could use and provide your Data Services Information to others in violation of the terms of the Agreement. We do not verify the contact information you provide for each Designated Recipient. Once you provide such contact information, until you terminate the designation, we will send Data Services Information to the contact information you have provided, and you are responsible for the accuracy of that information.
  • Your Designated Recipients may share your Personal Information with Dexcom for purposes relating to their use of Dexcom Products and Services, and we will use such Personal Information of yours in accordance with this Privacy Policy. If your Designated Recipients have your Personal Information, you hereby authorize them to provide such Personal Information to us as each determines.
  • Once you share any Personal Information with a third party, including third parties who are linked at our Website, we have no control over that Personal Information and how it is used by any such third party. You should refer to the terms of service, privacy policy and other provisions of the websites for each third party to which you provide any Personal Information.
  • You may elect for certain of our Software Apps to share glucose readings and other Personal Information with the Apple Health app and other third party products that store such readings. Once our Software App shares such readings and other Personal Information, we no longer have any control over such readings and other Personal Information and the use of or access to such readings and Personal Information, so you should understand the terms for the use of each third party products and the privacy policy applicable to each before you elect for our Software App to share any of your Personal Information with such third party or its products.

Cookies and Other Technologies

If you are a resident of the European Union, please visit About Cookies for information about our use of cookies and other tracking technologies with respect to your use of our Products and Services.

If you are a resident of the United States or any other jurisdiction outside of the European Union, below is a description of how we use cookies and other similar technologies in connection with our Products and Services.

  • Cookies:  Cookies are pieces of information stored directly on the computer that you are using.  Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Services.  We also use cookies to gather statistical information about use of the Products and Services in order to continually improve their design and functionality, to understand how they are used, and to assist us with resolving questions regarding them.  Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you use the Products and Services.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site.  You may also wish to click here for more information.  If, however, you do not accept these cookies, you may experience some inconvenience in your use of the Products and Services.  For example, we may not be able to recognize your computer, and you may need to log in every time you visit.

Our Products and Services do not currently have the ability to recognize or honor browser do-not-track signals. 

  • Analytics:  We may use third-party analytics, such as Google Analytics, in connection with the Products and Services.  Such third-party services may use cookies and similar technologies to collect and analyze information about use of the Products and Services and to report on activities and trends.  Such services may also collect information regarding the use of other websites, apps and online services.  For more information regarding Google Analytics, please click here.  You can download the Google Analytics opt-out browser add-on by clicking here .
  • Using pixel tags and other similar technologies:  Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some of our Products and Services to, among other things, track the actions of users (including email recipients), measure the success of our marketing campaigns, and compile statistics about use and response rates. 
  • Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies:  We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Products and Services.  If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time).  Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.

Interest Based Advertising:  We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Products and Services and other websites or online services, based on information relating to your access to and use of the Products and Services and other websites and services.  To do so, these companies may place or recognize a unique cookie on your browser (including through use of pixel tags).  If you would like more information about this practice and to learn about your choices in connection with it, please visit the Network Advertising Initiative opt out site and the Digital Advertising Alliance Self-Regulatory Program.

HIPAA

  • We may receive certain health information of yours that is “protected health information” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). When we receive protected health information, such information will be subject to the requirements under HIPAA and the HITECH Act, and the regulations effective under each of those Acts.

More on Privacy

  • Children’s Online Privacy Protection: Dexcom does not permit any person under 18 to subscribe directly to Dexcom Services or Software Apps or to directly purchase Dexcom Products. A parent or legal guardian may subscribe for a User who is under 18, but no person under 18 is permitted to use Dexcom Products or Services without the express agreement of a parent or legal guardian to the terms of the Agreement which require, among other things, that the parent or legal guardian is responsible for designating Designated Recipients, connecting the User Device to Dexcom Services or Software Apps,  interacting in all ways with Dexcom Services and Software Apps, and ensuring that all communications with us come from the parent or legal guardian and not from the person under 18.
  • Adults With Guardians, Conservators or Other Legal Supervision: Dexcom does not permit any person to subscribe directly to Dexcom Services, or Software Apps or to directly purchase Dexcom Products if that person lacks the legal competence to enter into a contract and be bound to the terms of the Agreement. A legal guardian, conservator or other person with the legal right to do so may subscribe for a User who lacks the legal competence to enter into a contract and be bound to the terms of the Agreement, but no such User is permitted to use Dexcom Services or Software Apps without the express agreement of a legal guardian, conservator or other person with the legal right to provide such agreement to the terms of the Agreement, which require, among other things, that such legal guardian or other person is responsible for designating Designated Recipients, connecting the User Device to Dexcom Services and Software Apps, interacting in all ways with Dexcom Services and Software Apps, and ensuring that all communications with us come from the such legal guardian or other person and not from the User who lacks legal competence.
  • Phishing: We do not and will not, at any time, request Registration Information in a non-secure or unsolicited email or telephone communication. Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a priority for us. For more information about phishing, visit the Federal Trade Commission website.
  • Security: Dexcom uses commercially reasonable standards of technology and operational security to protect Personal Information within our organization. Personal Information transmitted through Dexcom Products and Services is transmitted in encrypted form.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you feel that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section, below.
  • Links to Third Party Sites: Dexcom Products and Services may contain links to third-party websites, applications or other items. We assume no responsibility for the information practices of those websites, applications or other items, and the inclusion of a link does not imply our endorsement of the linked site or service. In addition, this Privacy Policy does not apply to the privacy, information, or other practices of any third parties, including any third party operating any site or service to which our Products or Services link or any third-party provider of an app, social media platform, operating system, wireless service or device. We encourage you to review each third-party’s privacy policy before disclosing any personal information to any third party or using its products or services.
  • Do Not Track Disclosure: In accordance with the Do-Not-Track amendments to the California Online Privacy Protection Act, we inform you that we do not currently respond to “do not track” signals or similar messages from your browser.
  • Retention: We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. 

Terminating Your Account

  • You may terminate your Dexcom account by following the instructions at the appropriate page at our Website. Followers may terminate their Follower status by canceling the User in the applicable Dexcom Service or by deleting the applicable Software App.
  • When you terminate your account, we may retain your Personal Information, and we may continue to use your Personal Information as authorized in this Privacy Policy. You may contact us at the email or mailing address listed in the “Contact Us” section below to request that we delete your Personal Information, and we will seek to remove your information from our active systems expeditiously.

Cross-Border Transfer

Dexcom Products and Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.  Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Dexcom Products and Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country. For personal information of customers that DexCom, Inc. receives from Affiliates and companies in the European Union and Switzerland, DexCom, Inc. has committed to handling such personal information in accordance with the Safe Harbor Principles. Click here to view the DexCom, Inc. Customer Safe Harbor Privacy Policy.

Changes

We may change this Privacy Policy by posting a new version of this Privacy Policy at www.dexcom.com/privacy-policy. When we update this Privacy Policy, we will update the legend at the top of this page to indicate the date that this Policy was last updated.  Any changes will become effective when we post the updated Policy on our Website.  Your use of our Products and Services following these changes means that you accept the updated Policy.  If you do not agree with any change, you may terminate your account as provided above and may choose not to submit any further Personal Information.

Contact Us

If you have any questions about this Privacy Policy or wish to "opt-out" of Solicitations, please: (1) send us an email at privacy@dexcom.com; or (2) write to us (and include your email address) at the following address:

Dexcom, Inc.
ATTN.: Privacy Officer
6340 Sequence Drive
San Diego, CA 92121, USA

Because email communications are not always secure, please do not include credit card information or sensitive information in your emails to us.

Version

This Privacy Policy is dated September 14, 2015.