Welcome to Klue, Inc. a wholly owned subsidiary of Medtronic MiniMed, Inc. (“Klue”). Privacy is very important to us. We also understand that privacy is very important to you. This Privacy Statement tells you how we protect and use information that we gather in connection with (i) your use and/or access to the klue.medtronic.com website; (ii) your use of and/or access to the Klue™ Health App (“App”); (iii) your use of and/or access to the Klue software to connect third-party wearable devices (“Software”) and (iv) your use of and/or access to any content or information and other wearable/mobile-enabled or online technology, digital tools and other services, software and products provided by us, including confidential materials, services, products, and features (including any related components, accessories, and documentation) currently under development by Klue based in the United States (collectively “Klue Services”). Klue and its affiliates, including Medtronic MiniMed, Inc. and our international affiliates, also operate other websites. This Privacy Statement does not apply to those other websites unless specifically indicated otherwise. You should review the privacy statement posted on other Medtronic websites when you visit them. The Klue Services and this Privacy Statement are intended for a U.S. audience.
By using Klue Services, you agree to the terms of the most recent version of this Privacy Statement. Please read our Terms of Use to understand the general rules about your use of Klue Services. Except as written in any other disclaimers, policies, terms of use, or other notices on this website or the App, this Privacy Statement and the Terms of Use are the complete agreement between you and Klue with respect to your use of Klue Services. You may be subject to additional terms that may apply when you access specific services or materials on certain areas in this website, or when you follow a link from this website.
Non-personal information is information that cannot identify you or be tied to you. We are always looking for ways to better serve you and improve this website. We will use non-personal information from you to help us make this website more useful to visitors. We also will use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information:
Personal information is information that we can use to specifically identify you, such as your:
We may keep and use personal information we collect from you through Klue Services to provide you access to our services. In addition, we may keep and use your personal information:
In using Klue Services and registering for an Account, you may receive periodic communication from Klue. The communications between you and Klue use electronic means. Klue may occasionally communicate with you via e-mail, phone or Notifications on your mobile device. By using Klue Services, you (1) consent to receiving electronic communications from Klue; and (2) agree that all terms and conditions, agreements, notices, disclosures, and other communications that Klue provides to you electronically satisfy any legal requirement that such communications would satisfy if it were to be in writing.
We will not share your personal information collected from this website with an unrelated third-party without your permission, except as otherwise provided in this Privacy Statement.
In the ordinary course of business, we will share some personal information with companies that we hire to perform services/functions on our behalf or provide Klue Services to users. For example, we may use different vendors or suppliers to support your use of Klue Services. In cases in which we share your personal information with a third-party, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.
We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting website visitors who violate our rules or engage in behavior which is harmful to other visitors (or illegal).
We may disclose your personal information to third parties if that the disclosure is necessary to:
Please note: In addition to the ways that we may keep, disclose, and use information described in this Privacy Statement, we also may keep, disclose, and use personal information in ways that we believe are consistent with governmental guidance, directions, regulations, and laws, including HIPAA and FDA requirements, where applicable.
If you visit our website to read or download information about one of our products or services, we may collect certain information about you from your computer. This information is collected from your computer's web browser. This information may include:
Cookies: We also may collect this information through cookies, pixels, web beacons, and similar technologies (“cookies”), that work through placing a small file (like a text file or graphic) in the browser files of your computer when you visit. The cookie may be stored on your computer's hard drive. Cookies are used to collect information for business purposes, such as enabling essential website functions and improving the user experience. We use both session cookies and persistent cookies. You are free to decline our cookies if your browser permits, but some parts of our website may not work properly for you if you do so. Klue may use third-party tracking and advertising providers to act on our behalf to track and analyze your usage of our sites. These third parties may collect, and share with us, as we may request, website usage information about visits to our sites, measure and research the effectiveness of our advertisements, and track page usage and paths followed during visits through our sites. Also, these third-party providers may place our Internet banner advertisements on other sites that you visit, and track use of our Internet banner advertisements and other links from our marketing partners' sites to our sites. To the extent the information collected on behalf of Klue by these third parties contains any personally identifiable information, we will protect it in accordance with this Privacy Statement.
We will not allow third parties other than those companies that we hire to perform services or functions on our behalf to place cookies on our website. Please refer to your browser Help instructions to learn more about managing cookies. And see below for an explanation of our use of cookies as well as how to opt out of our use of cookies.
For more information on third-party advertising-related cookies and how to opt out of some cookies as you choose, see the descriptions and links below.
You may opt-out of the use cookies through your internet browser’s plugins or privacy settings at any time, but this may impact the functionality of our website.
Click here to visit the Network Advertising Initiative site to set preferences and opt out of third-party targeting cookies
Klue Services require the use of a third-party wearable device. We collect personal information about your wearable device, such as the make and model, connection status, write preference, battery life, etc. We also collect personal information from your wearable device, which may include motion sensor data, heart rate, blood pressure, weight data, and temperature information. If you have enabled location services on your mobile device and/or your wearable device, we may also collect geolocation information to improve our App and services. We may also collect information, including historical information, from your mobile device or third-party applications through which you have granted access to your personal information, such as HealthKit.
We only collect information from your wearable device when you are logged into the Klue app. To stop the collection of device information, log out of the App on your mobile device. However, if you granted access to third party apps, we may collect historical data from such apps when you log back into your Klue account.
To use Klue Services, you must register for an Account. We collect personal information from you when you register for an account to use Klue Services. To establish your Account, we collect your email address and password. Your email address will be your Klue account username, which you will use to log into your account. The information in this section applies to your account:
Personal Information Collected Through Your Profile. We collect personal information when you create a Klue Account profile (“Profile”). To establish your Profile, we may collect personal information you choose to provide us. We may also collect information about your health, lifestyle, and eating and drinking behaviors. You can choose not to provide us with certain personal information on your Profile, but please be aware that may restrict your access to certain Services and/or impact the Services provided to you.
Viewing/Editing Personal Information: You may change the information you have provided on your Profile by logging into your account and editing the information.
Storage of Personal Information: Klue, Medtronic Diabetes or their vendors providing services in connection with the Klue Services, may store your personal information on servers in countries where Medtronic Diabetes operates, including a server(s) located in the United States of America. If you choose to close your account, we will maintain copies of your information in our internal records, systems, and databases, in accordance with our data retention schedules. We will continue to treat your personal information in accordance with this Privacy Statement.
Protecting Personal Information: We take security seriously and take a number of steps to protect your personal information. You also play a big part in protecting the privacy of your personal information. When you create an account, we ask you to select a password that is unique to you. To protect your personal information from unwanted disclosure, you should not give your password to anyone with whom you would not share your personal information. Our website may also log you out after a period of inactivity and require you to log in again. When you are ready to leave this website, always “log off” and close your browser to help protect the confidentiality of your information.
If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made. By continuing to use or access our website after those changes become effective, you agree to be bound by the revised Privacy Policy. Significant changes are also described below.
Recent revisions to the Privacy Statement:
This Privacy Statement was last revised on May 14, 2020 following Medtronic’s acquisition of Klue, Inc. Click here to read Klue’s previous privacy policy.
This website may contain links to other websites. Some of those websites may be operated by Klue or its affiliates, and some may be operated by third parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. We are not responsible for the performance of websites operated by third parties or for your business dealings with them. Therefore, whenever you leave this website, we recommend that you review each website's privacy practices and make your own conclusions regarding the adequacy of these practices.
We may contact you periodically by e-mail, mail or telephone, if you agree to that method of contact, in order to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this website allow you to communicate with us using an online form. If your communication requests a response from us, we will send you a response via e-mail. The e-mail response or confirmation may include your personal information, including personal information about your health, your name, address, etc. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.
We care about protecting the online privacy of children. The Klue Health App is only available to users over the age of 18. We will not intentionally collect any personal information (such as a child's name or e-mail address) from children under the age of 13. If you have questions about a child’s personal information, please contact us here.
Security is very important to us. We also understand that security is important to you. We take reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
If you have questions or comments about this Privacy Statement, please contact us here.
Supplemental Privacy Notice for California Residents
This notice for California residents supplements the information contained in our Privacy Statement and applies solely to residents of the State of California “Supplemental Notice”. We adopt this Supplemental Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Supplemental Notice. Under the California Consumer Privacy Act (“CCPA”), you have certain rights in relation to some of your personal data, including the right to certain disclosures and explanations of rights. This section explains your rights under California law.
California law (CalOPPA) requires us to let you know how we respond to web browser 'Do Not Track (DNT) signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not honor Do Not Track requests at this time.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“personal information”). We may have collected the following categories of personal information from consumers through our websites, apps, services, devices, or other services within the twelve (12) months preceding the effective date of this Privacy Statement:
Personal Information Category
“Personal information” under the California Consumer Privacy Act does not include information that is
For additional information, please see How Do We Keep and Use Personal Information.
We obtain the categories of personal information listed above from the following categories of sources:
In the past 12 months, we have used or disclosed the personal information we collect for our operational purposes and for one or more of the following business purposes:
Please see How Do We Keep and Use Personal Information in our Privacy Statement for more information.
We will not share consumers’ personal information with an unrelated third party without permission, except as described below. We may share personal information with any member of our corporate group, including parent companies, subsidiaries, and affiliates, and other companies in which we have an ownership or economic interest for purposes that are consistent with those identified in our Privacy Statement and this Supplemental Notice.
In the ordinary course of business, we will share some personal information with companies that we hire to perform services or functions on our behalf. In all cases in which we share consumers’ personal information with a third party, we will only allow them to keep, disclose, or use consumers’ information to provide the services we asked them to provide.
We may be required to release consumers’ personal information in response to a court order, subpoena, search warrant, law, or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior which is harmful to other users or illegal. In addition, we may keep, disclose, and use consumers’ personal information in order to comply with U.S. FDA and other governmental guidance, directions, regulations, and laws.
We do not sell personal information of California consumers.
This does not include disclosures that are not a “sale” under the CCPA, including when
We do not sell personal information of California consumers, including minors.
You may access, change, correct, or update any of your personal information in your Account by editing your profile within your account (if this feature is available to you. If you are a California resident and you want to submit a request or inquiry to us regarding your California rights, you or your authorized agent can contact us here or call us at 1‑866‑639‑6907 starting January 1, 2020. You do not have to create an account with us to submit a request.
Your request will be confirmed within ten days of receipt and we will respond within 45 days. If we need more than 45 days, we will notify you that your request is being delayed.
We can only respond to your request if it is verifiable. This means we are obligated to take reasonable steps to verify your identity or your authorized agent’s authority and your right to access the information you request. We may ask for additional information that will help us do so. We will only use that additional information in the verification process, and not for any other purpose.
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.