HappyZone Blood Glucose Monitoring Service Privacy Policy
Viewtel Inc. (hereinafter referred to as "Viewtel") establishes and discloses the following Privacy Policy to protect the personal information of individuals collected and used during the use of the Viewtel Blood Glucose Monitoring (Glucose Monitoring System, hereinafter referred to as HappyZone) service and to promptly and smoothly handle any related complaints, in accordance with Article 30 of the Personal Information Protection Act of the Republic of Korea.
The term “Service” refers to the services provided by Viewtel, including the mobile app (App) for the HappyZone blood glucose meter and the web (Web) application that helps manage blood glucose levels in conjunction with health managers based on the collected data.
The term “Data Subject” refers to an individual who can be identified by the processed information, meaning the person to whom the information pertains. “Personal Information” refers to information about a living individual that can identify a specific person by name, resident registration number, images, etc., information that cannot identify a specific person by itself but can be easily combined with other information to identify a person, or information that cannot identify a specific person without the use or combination of additional information to restore it to its original state.
Viewtel is committed to protecting the freedoms and rights of data subjects by complying with the relevant laws and regulations, including the Personal Information Protection Act of the Republic of Korea. We handle personal information lawfully and manage it securely.
In accordance with Article 30 of the Personal Information Protection Act, we establish and disclose the following Privacy Policy to protect personal information and to address related complaints promptly and smoothly.
Viewtel ensures that this Privacy Policy is accessible to users of the HappyZone service by publishing it in the App menu or on the website related to the service.
This policy will be effective from September xx, 2024, and any amendments will be announced to users via the website's notice section.
Viewtel processes personal information for the following purposes. The collected personal information will not be used for purposes other than those outlined below. If the purposes of use change, we will take necessary actions, such as obtaining separate consent, in accordance with Article 18 of the Personal Information Protection Act and other relevant laws.
To identify individuals and manage memberships, we use personal information:
To provide blood glucose management services, we use personal information:
To improve services, we use personal information for:
To handle customer inquiries, we use personal information for:
For personalized advertising and marketing (with user consent), we use personal information for:
Additional Use and Provision
In accordance with Article 15(3) and Article 17(4) of the Personal Information Protection Act, and considering the provisions of Article 14-2 of the Enforcement Decree of the Personal Information Protection Act, Viewtel may use or provide personal information additionally without the consent of the data subject. Accordingly, Viewtel has considered the following factors for additional use or provision without the data subject's consent:
During membership registration or while using the service, we collect the minimum personal information necessary to provide the services through our website, individual applications, or programs. The items of personal information collected include:
|
Services |
Items of Personal Information Collected |
|
Viewtel Integrated Member Account Management Site |
[Required] Name, Email Address (ID), Password, Date of Birth, Gender, Mobile Phone Number, Profile Picture, Country of Residence, Language, User Validity Token Information, Device Management Information (Device Model, Device OS Information, Device Unique Identifier), Access IP Information, Log Data, Cookies, Usage Time |
|
Happy Zone APP |
[Required] Connected Self-Blood Glucose Meter Information, Inquiry Details, Event Information (Meal Quantity, Exercise Amount, Notes, Photos), Sensor Information (Sensor Unique Identifier, PIN Code, Hardware Version, Software Version, Model Number, Lot Information, etc.), Mobile Device Information (Device Model, OS Information, Notification Activation Status, Bluetooth Activation Status), App Settings Information (App Name, Version, Package Name, Installation Date, Permissions, Database Version, Local Settings Information, etc.), Log Data, Cookies, Usage Time
[Sensitive Information (Required)] Blood Glucose (Self-Measurement for Sensor Calibration), Notification Information, Usage Event Log Information, Event Information (Blood Glucose, Ketones, Insulin, Oral Medication), Type of Diabetes |
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During the use of the service, the following personal information may be generated and collected: Automatically Generated Information: Records such as app installation and deletion Such automatically generated information is processed with the user’s consent, but it may be automatically created and collected during the use of mobile apps, computer web, and other platforms. |
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Viewtel collects the above personal information as users agree to its collection and use during service registration or login. Users may choose not to consent to the collection and use of this information; however, if users do not agree to the collection and use of essential information and sensitive information (required), access to certain services may be restricted.
Viewtel processes and retains personal information within the retention and usage periods specified by law or agreed upon with the data subject at the time of collection. The retention and usage periods for each type of personal information are as follows:
Personal Identification and Membership Management: Until membership withdrawal
However, in the following cases, information will be retained until the respective reason is resolved:
HappyZone Service Provision/Improvement and Customer Inquiry Handling: Until membership withdrawal
However, in the following cases, information will be retained until the respective reason is resolved:
Viewtel destroys personal information without delay when it is no longer necessary due to the expiration of the retention period or the achievement of the purpose of processing. However, if there are legal requirements or user requests that necessitate the continued retention of personal information (refer to ‘4. Retention and Usage Period of Personal Information’), such personal information will be transferred to a separate database (DB) or stored in a different location. Personal information transferred to a separate database or storage location will not be used for purposes other than those required by law.
Destruction Procedure
Viewtel selects the personal information that needs to be destroyed and obtains approval from Viewtel’s Chief Privacy Officer before proceeding with the destruction.
Destruction Method
For Personal Information Stored in Electronic Files: The information is deleted using technical methods that prevent the recovery of the records.
For Personal Information Recorded on Paper: The information is shredded using a shredder
Viewtel will transition users who have not used the service for one year to a dormant account status and will separately store their personal information. The separated personal information will be retained for one year and will be destroyed unless required otherwise by specific laws.
Viewtel informs users who are about to transition to a dormant account about the fact of separate storage, the date of the transition, and the items of personal information to be separately stored. This notification is sent via email, SMS, or other methods that can reach the user, at least 30 days before the transition.
If users do not wish to transition to a dormant account, they can log in to the service before the transition occurs. Additionally, even if the account has been transitioned to a dormant status, if the personal information has not been destroyed, users can restore their dormant account and continue to use the service normally by logging in and consenting to the restoration.
Viewtel provides personal information to third parties only in cases where user consent is obtained or as specifically required by law under Articles 17 and 18 of the Personal Information Protection Act. Personal information will not be provided to third parties without user consent in other cases.
If a user wishes to use services from external partners, Viewtel will obtain explicit consent from the user and provide personal information to external partners only within the minimum necessary scope. To see the external partners to whom Viewtel currently provides user personal information, please click here. If there are additions or changes to the third parties receiving personal information, user consent will be obtained, and notifications will be made through website announcements (or individual notices via email or other methods).
In accordance with the "Emergency Personal Information Processing and Protection Guidelines" issued jointly by government agencies, Viewtel may provide personal information to relevant authorities without the data subject's consent in emergency situations such as disasters, infectious diseases, imminent threats to life or physical safety, or urgent property losses. For more details, please click here.
Viewtel outsources some of its tasks to external parties to provide more convenient and better services. Viewtel ensures that the outsourced companies comply with the Personal Information Protection Act, Article 26, which includes prohibitions on the processing of personal information beyond the scope of the outsourced work, implementing technical and managerial protection measures, restrictions on re-outsourcing, management and supervision of the subcontractor, and liability for damages. These requirements are stipulated in contracts or other documents, and Viewtel supervises whether the subcontractors handle personal information securely. If users do not use services related to the outsourced tasks, their personal information is not provided to the subcontractors.
Outsourcing of Personal Information Processing
Currently, the external companies to which Viewtel outsources the processing of personal information are listed below. If there are any changes in the content of the outsourced work or the subcontractors, we will notify you through website announcements.
To fulfill service obligations, Viewtel outsources personal information processing tasks to specialized foreign companies as detailed below. As mentioned in section ‘8. Outsourcing of Collected Personal Information,’ when outsourcing the processing of personal information, Viewtel supervises the subcontractors to ensure that personal information is handled securely and in compliance with privacy protection standards.
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Items of Personal Information Transferred |
Name, Email Address (ID), Password, Date of Birth, Gender, User Authentication Token Information, Device Management Information (Device Model, Device OS Information, Device Unique Identifier), Access IP Information, Connected Sensor and Blood Glucose Monitor Information, Inquiry Details, Sensor-Measured Blood Glucose Event Information (Blood Glucose, Ketones, Insulin, Oral Medications, Meal Intake, Physical Activity, Notes) |
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Countries and Locations of Transferred Personal Information Date and Method of Transfer |
Germany [Include Detailed Address if applicable] At the time of each member’s registration, blood glucose measurements, and other service usage. Data is moved through a secure, enhanced private network Transmission using the Internet network processed with security protocols (SSL) |
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Recipients of Transferred Personal Information |
[Check and write in detail] |
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Outsourced Task Details |
Personal Information Storage and Processing via Cloud |
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Retention and Use Period |
Until Membership Cancellation |
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Methods, Procedures, and Effects of Refusing Personal Information Transfer |
Data subjects can refuse the transfer of their personal information abroad by contacting Viewtel's Personal Information Protection Department. However, please be aware that if you refuse the transfer of personal information abroad, it may hinder the smooth processing of services. |
Viewtel will only disclose users' sensitive information to the National Health Insurance Corporation or third-party service providers with the user's explicit consent. Except in cases where users have given separate consent or where disclosure is mandated by law, Viewtel will not disclose users' sensitive information.
Users can choose not to consent to the disclosure of their sensitive information to third parties. In such cases, sensitive information will not be shared with third parties.
Users may contact the Personal Information Protection Department or the designated person below for inquiries regarding the scope of sensitive information disclosure, or to request changes to or opt-out of disclosure settings:
Users and their legal representatives have the following rights regarding the personal information registered with Viewtel:
If users have integrated external account services with their Viewtel service account, they can unlink external accounts from the 'Member Information' section. Modifications to information collected via external accounts (e.g., Google, Kakao) should be made on the respective external account management pages. Deletion of information will occur when the linked Viewtel account is deleted.
Users may exercise the above rights by contacting Viewtel's representative telephone number (031-707-0314) or the Personal Information Protection Officer via email at sales@view-tel.co.kr. Requests can be made in writing, by phone, or by email.
Please note that the rights to view, transmit, and suspend the processing of personal information may be restricted under Article 35(4), Article 35-2(6), (7), and Article 37(2) of the Personal Information Protection Act. Viewtel will verify that the person requesting access, transmission, correction, deletion, or suspension is either the user or a legitimate representative.
If a user requests correction of personal information errors, Viewtel will not use or provide the incorrect information to third parties until the correction is completed. If incorrect personal information has already been provided to a third party, Viewtel will promptly notify the third party of the correction. However, if the personal information is specified as required under other laws, deletion may not be requested.
Viewtel utilizes cookies and similar technologies to store and retrieve users' information. A cookie is a very small text file sent by the server operating Viewtel's website to the user's browser, which is then stored on the user's computer hard drive or mobile device.
Purpose of Using Cookies
Cookies are used for implementing automatic login functionality, analyzing the frequency of visits or the duration of visits for both members and non-members, understanding and tracking user preferences and interests, and providing targeted marketing and personalized services by monitoring participation in events and visit frequency.
How to Refuse Cookies
Users have the option to accept or refuse the installation of cookies. This can be managed through browser settings, where users can choose to allow all cookies, receive a notification each time a cookie is stored, or refuse all cookies.
However, refusing cookies may result in difficulties in providing certain services.
For example, in Microsoft Edge, you can configure the settings as follows.
Go to the "Settings" menu. Select "Cookies and site permissions."
Click on "Manage and delete cookies and site data." Here, you can set specific controls for cookies.
Go to the "Settings" menu. Select "Cookies and site permissions."
Click on "Cookies and stored site data." Click "See all cookies and site data" to view them.
Go to the "Settings" menu. Select "Cookies and site permissions."
Click on "Manage and delete cookies and site data" to block cookies.
Viewtel processes personal data in a pseudonymous form to pursue business objectives such as statistical analysis, academic research, public record preservation, market research, and the development of better products and services. Pseudonymous information is processed in a way that it cannot identify specific individuals and is handled as follows.
Pseudonymous information is separated from additional data to prevent re-identification and is stored and managed separately. Necessary technical and administrative protection measures are implemented to safeguard pseudonymous information. For more details on our general policies regarding the processing of personal data, refer to section ‘14. Other Policies on Personal Data Processing’.
Matters pertaining to the processing of pseudonym information
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Categori- zation |
Purpose of Processing |
Processing Items |
Retention and Use Period |
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Statistical Analysis |
Demographic Statistics, Usage Patterns Analysis, and Research Provided by Viewtel's Happy Zone |
Profile (gender, age, etc.), blood sugar value, measurement time information, device information, event input information |
Until Membership Cancellation |
|
Academic Research |
Research on the Effectiveness of Blood Sugar Improvement Based on Usage Patterns of Viewtel’s HappyZone |
Profile (gender, age, etc.), blood sugar value, measurement time information, device information, event input information |
Until Membership Cancellation |
Technical and Managerial Measures to Ensure the Safety of Personal Data
Viewtel takes the following measures to ensure the safety of personal data:
Viewtel has established and implements internal management plans to ensure that personal data is not lost, stolen, leaked, altered, or damaged. This involves taking various technical and managerial measures to protect data. The company also has an internal data protection unit to oversee and enforce data protection measures. If any issues are detected, immediate corrective actions are taken.
Viewtel utilizes intrusion prevention systems to control unauthorized access from external sources and strives to equip all possible technical devices to secure system integrity.
Viewtel maintains and manages records of access to its personal data processing systems, using security features to prevent forgery or alteration of these records.
Users' personal data is protected by passwords and is encrypted for file storage and transmission. Data is managed using encryption techniques or file-locking features, and critical data is protected through additional security functions.
Viewtel takes steps to prevent damage from computer viruses by using antivirus programs. These programs are regularly updated, and any newly emerging viruses are promptly addressed with updates to prevent personal data breaches.
Viewtel adopts secure encryption protocols (SSL) to ensure the safe transmission of personal data over networks using encryption algorithms.
To safeguard against external threats such as hacking, each server is equipped with intrusion prevention systems and vulnerability analysis tools to ensure robust security.
Personal data is stored separately from general data and is managed on separate servers to maintain data integrity and security.
Viewtel restricts access to users' personal data to only those employees who are directly involved in marketing activities, the data protection officer, and those engaged in personal data management tasks, as well as other individuals for whom handling personal data is unavoidable for their work.
Regular internal training and external training programs are conducted for employees who handle personal data to ensure they acquire new security technologies and understand their obligations regarding personal data protection.
At the time of hiring, all employees sign a confidentiality agreement to prevent information leaks caused by individuals. Internal procedures are in place to audit the implementation of the personal data protection policy and compliance by employees.
The transfer of responsibilities related to personal data handling is carried out thoroughly while maintaining security, and responsibilities related to personal data incidents are clearly defined for employees upon joining and leaving the company.
Special protection zones, such as computer rooms and data storage areas, are established to control access and ensure their security.
Posting Policy
Viewtel values users' posts and makes every effort to protect them from tampering, damage, or deletion. However, the following types of posts are exceptions:
To promote a positive posting culture, Viewtel may edit or remove specific portions of posts that disclose personal information without consent, or modify them with symbols. If the content can be relocated to a different board, Viewtel will provide information on the relocation to avoid confusion. In other cases, posts may be deleted after an explicit or individual warning.
Fundamentally, all rights and responsibilities related to posts lie with the individual who created them. Additionally, information voluntarily disclosed through posts is difficult to protect, so users are advised to carefully consider the information they share before posting.
Viewtel has appointed a Privacy Officer to oversee the handling of personal information and address any concerns, complaints, or issues related to personal data processing. For inquiries, complaints, advice, or other matters related to privacy protection during your use of our website or services, please contact the Privacy Officer or the relevant department as detailed below.
Chief Privacy Officer
Privacy Protection Department and Contact Person
Request for Access to Personal Information
Users can request access to their personal information in accordance with Article 35 of the Personal Information Protection Act from the designated department. Viewtel will make every effort to process requests for access to personal information promptly.
Users who experience any issues related to the protection of personal information while using Viewtel's services may report them to the Privacy Officer or the relevant department. Viewtel will respond to such reports. For other complaints or consultations regarding personal information infringements, please contact the following organizations:
Viewtel will notify users of any additions, deletions, or modifications to this policy through announcements on our website.
Additional Clause
This Privacy Policy is effective as of October 1, 2024.