Last updated: 08/2024

DTP Solutions is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. In this Privacy Policy, we may refer to ourselves as “we”, “us” or “our”, by which we mean DTP Solutions and its subsidiaries. The controller of your data is the DTP Logistical Solutions Ltd, a corporation duly organized and existing under the laws of Ireland (“DTP Solutions”), registered at  Suite A, Elm House, 6 Millennium Park, Osberstown, Naas, Co. Kildare, W91 R2H, Republic of Ireland.  

This Privacy Policy describes our practices that we or our service providers collect through the website operated and controlled by DTP Solutions, through which you are accessing this Privacy Policy (the “Services”) or if you contact via e-mail at admin@dtp-solutions.ie 

Please read this entire Privacy Policy before using any of the DTP Solutions Services.

PURPOSE OF DTP’S CONFIDENTIALITY POLICY

The purpose of this confidentiality policy is to:

    • to explain why DTP Solutions collects various types of data;
    • to understand how your data will be processed;
    • to ensure control of your data, by facilitating the exercise of your rights.
    • to describe how we collect, use, protect and process the Personal Data we collect about you.

    For all data controllers, it contributes to the fair processing of data and helps to establish a relationship of trust with all of our company’s stakeholders.

    PERSONAL DATA

    The term “Personal Data” in this Privacy Policy means any information which could identify you as an individual, either directly (for example, your name) or indirectly (such as an IP address or other unique identifier).

    DTP Solutions may collect and process the following Personal Data when you use the Services:

      • contact details (such as name, address, email address, telephone number);
      • demographic information (such as date of birth, gender);
      • job title and place of work;
      • account-related information (such as the password you select to use the Services or the serial number of any devices associated with the account);
      • complaint or adverse event information;
      • your preferences (such as communication, language and time zone).

      DATA COLLECTED 

      We undertake to collect only the data that is strictly necessary for the achievement of the purposes previously stated and not to use it for other purposes without prior consent. 

      We only collect the following necessary data: Name, Position held (e.g. nurse), Professional delivery address, Email address, Telephone number.

      When you are asked to provide your Personal Data you may have an option to choose not to provide it but if you do so, it may inhibit our ability to provide some elements of the Services to you.

      If you are providing information of someone other than yourself then you are confirming to us that you have any legally required authorization, consent or other lawful authority to share the other person’s information and for us to use it in accordance with this Privacy Policy.

      If you are a healthcare professional, DTP Solutions may collect:

        • your professional qualifications, educational and professional history, professional and government affiliations, information included on a resume, languages spoken, information about publications with which you have been involved;
        • information about products and activities with which you have engaged;
        • details about our interactions with you, your prescribing of our products;
        • information collected in connection with DTP Solutions events, training or activities you have attended or with which you have been involved; and
        • public information such as license information and other due diligence related information.

        We may combine information you provide with information from other sources, for example social media or from public sources.

        HOW DTP Solutions COLLECTS PERSONAL DATA

        DTP Solutions collects Personal Data in a number of ways, including:

          • directly from you or your authorized representative, for example, when you sign up for an account for one of the Services;
          • when you use one of our Services;
          • when you share your social media profile with DTP Solutions or use it to contact us;
          • when you respond to DTP Solutions surveys or promotions, where permitted;
          • when you contact DTP Solutions regarding fulfillment and care of orders; 
          • when you share complaints or adverse event information with DTP Solutions;
          • when you authorize third parties to provide your information to us;
          • from other products, services or applications that are integrated with our Services (such as, for example, when a third party product, service or application is linked with our Services or vice versa);
          • from public or third party information sources;
          • from third party service providers or our business partners;
          • from social media, for example mentioning a DTP Solutions product or service in a Tweet. We encourage you to read the Privacy Policies of the social media platforms that you use;
          • if you are a healthcare professional, if you engage with one of our sales representatives, attend an online or live event such as a conference, training or advisory board meeting; and
          • indirectly through tracking technologies, including over time and across third-party websites and online services. We may also automatically collect information about you from website interaction, analytics partners, and other parties.

          HOW DTP SOLUTIONS USES PERSONAL DATA

          We process your health information when you use the Services on the basis of your explicit consent.

          We use your Personal Data for the following purposes where it is necessary for us to perform our Services to you:

            • manage your account on our Services;
            • provide our products or the Services to you;
            • provide fulfillment support to you; and
            • send you important information regarding our relationship with you or regarding changes to our terms of use and other policies or administrative information, such as planned maintenance or downtime;

            ORDER PROCESSING 

            We collect your personal data to enable you to receive the One Touch blood glucose meter and the consumables needed to serve your patients. No patient health data is collected or processed by our services. This information enables us to create and manage your account, to facilitate your orders and to offer you the possibility of modifying them according to your needs. The main purpose is to prepare, pack and deliver your supplies.

            We use your Personal Data for the following purposes where it is necessary in our legitimate interests in order to:

              • operate our business;
              • improve our products and Services;
              • respond to your enquiries and fulfill your requests, such as to send you documents you request or e-mail alerts;
              • invite you to provide feedback on our products and/or services;
              • personalize your experience when you interact with us;
              • undertake market research, analytics or segmentation so that we can better understand your needs and so that we can: improve our products and services; understand the effectiveness of our marketing campaigns and to tailor our communications with you;
              • in connection with our cybersecurity efforts; and
              • to ensure continuity of service to you if we sell, assign or transfer part of our business or enter into a relationship with a distributor.

              MARKETING PROSPECTING 

              With your consent, your personal data can be used to send you marketing prospecting emails from LifeScan companies including LifeScan Healthcare Ireland Ltd. You may withdraw your consent at any time by contacting: contact@myonetouch.ie

              We use your Personal Data to provide you with information about our products and services or the products and services of selected third-party partners, provided that you have opted-in to receive such communication, where an opt-in is required by law. If you have opted-in to receive such communications, our legal basis for processing your Personal Data for this purpose is your consent.

              REPORTING AND STATISTICS

              Your anonymized personal data is also used for reporting and statistical purposes. These analyses help us to improve our services, better understand our customers’ needs and optimize our internal processes.

              We use your Personal Data for the following purposes in order to comply with a legal obligation that we are subject to, or where necessary to establish, exercise or defend legal claims:

                • comply with legal or regulatory obligations to which DTP Solutions is subject, such as reporting complaints or adverse events; anti-corruption; trade compliance or transparency reporting requirements for healthcare professionals; and
                • to defend DTP Solutions against actual, potential or threatened litigation.

                We may also use your Personal Data in other ways, with your consent.

                HOW DTP SOLUTIONS SHARES PERSONAL DATA

                We may share your Personal Data:

                  • with other LifeScan companies including LifeScan Healthcare Ireland Ltd incorporated and registered in the Republic of Ireland with registration number 672030 whose registered office is at 10 Earlsfort Terrace, Dublin 2, D02 T380, for the purposes described in this Privacy Policy. However, the Controller is the party responsible for the management of your Personal Data.
                  • with your authorized health care provider (such as a clinic, pharmacy or healthcare professional), payor or to other third parties that you choose to provide access to your Personal Data. Some of our Services permit you to share all of the information you enter within the particular Service or to share certain information with a relative, friend or caregiver;
                  • when you provide your consent for us to do so, for example with third party partners with whom we offer a co-branded or co-marketed promotion;
                  • with our third-party service providers who provide services to you or us such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer care, e- mail and direct mail delivery services, credit card processing, auditing services, and other services, in order to enable them to provide services to you or us;
                  • with third parties or business partners where you choose to integrate their products or services with the Services;
                  • with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
                  • with third parties or service providers involved in the provision of advertising and analytics;
                  • for our business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our products and services, identifying usage trends, where permitted, personalizing your experience by presenting products and offers tailored to you, and determining the effectiveness of our promotional campaigns;
                  • as otherwise described to you at the time of collection;
                  • after your order, your delivery data will be shared with our delivery service provider for product delivery;
                  • third parties involved in the fulfillment of your orders, such as for example to coordinate with our prescription, shipment, and logistics providers.
                  • our business partners, such as for example when you link our Services with a partner’s product, application, or service (or vice versa).

                  In addition, we may use and disclose information collected through our Services as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect the operations of LifeScan group companies; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

                  This data will also be used for reporting and statistical purposes if you have given your consent and will be stored in DTP Solutions’ internal file management.

                  For marketing communications, emails will be sent via Marketing Cloud (Salesforce) only to users who have given their consent to receive marketing communications.

                  ACCESS TO DATA 

                  Only DTP and the delivery service provider have access to the data.  The Data is also stored on the website and that of the delivery service provider once online. The website is hosted on Google servers in London, UK. There is an EU post-Brexit agreement for the transfer of personal data to and from the UK. Reports exported to spreadsheets are on Google/Microsoft servers in Europe. For the DTP Solutions part, there is no transfer to the USA.

                  OTHER PRODUCTS, SERVICES 

                  The Services may include functionality that allows for links to or integrations with the products, services or apps of our business partners (“Partner Apps”). In the event that you use Services that include such functionality, our business partners’ privacy policies will govern how they handle your Personal Data in connection with such Partner Apps, while this Privacy Policy will continue to govern how we handle your Personal Data. We are not responsible for our business partners’ privacy practices, and you should review the applicable Partner App privacy policies before using such functionality.

                  EMAIL COMMUNICATIONS

                  Where you agree, we may send you email messages promoting our Services or with other information about our programs and offers. As further described below under “Your Privacy Rights and Choices,” you may opt out of these messages at any time by contacting us or by using the “My Account” or “Settings” function if applicable.

                  COOKIES, INTERNET-BASED ADVERTISING AND OTHER TOOLS

                  We use persistent identifiers to authenticate you to the Services to analyze how the Services are used, to link information about how you use the Services with your account, to analyze the effectiveness of our messaging and to help to tailor our products and the Services. We may also use persistent identifiers to identify you across other media or through your use of our other products or the Services to help to tailor our offerings and to provide enhanced personalization and communications.

                  Cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on a website, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using a website. We also use cookies to recognize your computer or device, which makes your use of the Services easier, such as to remember what is in your shopping cart. In addition, we use cookies to gather statistical information about usage of our Services in order to continually improve design and functionality, understand how individuals use them and to assist us with resolving questions regarding the Services. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are using the Services. We may also use cookies in online advertising to track consumer responses to our advertisements. 

                  You can refuse to accept these cookies by following your browser’s instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Site. In addition, you may not receive advertising or other offers from us that are relevant to your interests and needs. To learn more about cookies, please visit http://www.allaboutcookies.org.

                  Using pixel tags, web beacons, clear GIFs, or other similar technologies. These may be used in connection with some web pages and HTML-formatted e-mail messages to, among other things, track the actions of users and e-mail recipients, measure the success of our marketing campaigns, and compile statistics about usage and response rates.

                  Analytics. We may use certain analytics providers such as Google Analytics and Firebase Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. The Services may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to: http://www.google.com/policies/privacy/partners and opt out of them by downloading the Google Analytics opt- out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

                  Retargeting of Advertisements and Opting Out. We try to deliver relevant advertisements by using a common form of online advertising known as “retargeting”. Retargeting provides advertisements on a website based on a user’s activities on a different, unrelated site. To enable this, LifeScan or its advertising service providers may use a device ID, cookie, pixel, web beacon or similar technology placed by DTP Solutions or its third- party service provider when you visit our Services. The placing of these cookies or other technologies on your device may enable you to be identified across multiple websites.

                  You can opt-out of having your online activity collected for advertising purposes and receiving behaviorally targeted advertisements by using the links below:

                    Please note that the choices you make are specific to the browser and device on which you implement such controls.

                    Mobile advertising identifier controls. Apple and Android mobile devices generate an advertising identifier that can be accessed by apps and used by advertisers in a way similar to how cookies are used on websites. Apple and Android operating systems provide options to limit tracking.

                    Do Not Track. Some browsers have a Do Not Track (“DNT”) feature that allow a user to indicate a preference not to have their online activities tracked. If you limit a website’s ability to set cookies, your user experience may be affected. The DNT function is not available when you are accessing the Services through a mobile application rather than through the relevant website.

                    YOUR PRIVACY RIGHTS AND CHOICES

                    Depending on the laws in your country, you may have rights to:

                      • withdraw your consent to us processing your Personal Data for direct marketing;
                      • obtain confirmation as to whether or not your personal data is being processes and if so, access to this data;
                      • obtain copies of your Personal Data and additional information about the processing of your data;
                      • request the rectification of inaccurate data concerning you;
                      • correct any inaccurate or incomplete information about you which we hold;
                      • request deletion of your Personal Data. This right is subject to certain exclusions such as compliance with legal or regulatory obligations;
                      • restrict processing of your Personal Data. This right is subject to certain restrictions;
                      • object to processing of your Personal Data. This right is subject to certain restrictions;
                      • ask us to transfer your Personal Data to another organization, under certain circumstances; and
                      • make a complaint to a privacy regulator.

                      EXERCISING YOUR RIGHTS

                      In accordance with current regulations on the protection of personal data, you have the following rights:

                      Right of access: You can obtain confirmation as to whether or not your personal data is being processed, and if so, you can access this data. 

                      Right of rectification: You may request the rectification of inaccurate data concerning you. 

                      Right to erasure: You may request the deletion of your personal data subject to legal retention obligations. 

                      Right to restrict processing: You may request the restriction of the processing of your personal data.

                      Right to portability: You may receive your personal data in a structured, commonly used and machine-readable format. 

                      Right to object: You may object, on legitimate grounds, to the processing of your personal data.

                      Data Controller, 

                      DTP Solutions,
                      Suite A,
                      Elm House,
                      6 Millennium Park,
                      Osberstown,
                      Naas,
                      Co. Kildare,
                      W91 R2H1,
                      Ireland

                      Email: admin@dtp-solutions.ie  

                      Irish Data Commissioners details: 

                      Data Protection Commission
                      21 Fitzwilliam Square South
                      Dublin 2
                      D02 RD28
                      Ireland

                      Additionally, the DPC’s contact information for completeness:

                      Telephone: +353 57 868 4800 / +353 76 110 4800
                      Email: info@dataprotection.ie
                      Website: www.dataprotection.ie

                      In order to protect your Personal Data, we may require that you provide evidence to confirm your identity before we provide the requested information. We will respond to your request within the relevant time limit under applicable law.

                      To exercise these rights, please contact us at the following address/contact form by email at admin@dtp-solutions.ie or by post at DTP Solutions, Suite A, Elm House, 6 Millennium Park, Osberstown, Naas, Co. Kildare, W91 R2H1

                      If you wish to opt-out of receiving marketing emails from DTP Solutions, you may update your preferences by sending an email to your Customer Care email address: admin@dtp-solutions.ie or, where there is a “My Account” or Settings feature, you can update your marketing preferences there. If you choose to opt-out of receiving such messages, we may still send you service-related announcements such as changes to the Privacy Policy, planned maintenance or downtime.

                      DE-IDENTIFIED, PERMANENTLY ANONYMISED, AND AGGREGATED DATA

                      We take steps to transform personal data into a format where the identity of the individual cannot be traced. This process includes anonymization and de-identification, carried out using irreversible methods that guarantee the impossibility of re-associating the data with an identifiable person.

                      The legal basis for this processing is our legitimate interest in carrying out statistical analyses and research, and in improving our services, while guaranteeing your confidentiality. We apply rigorous technical and organizational measures to ensure the integrity and security of this process.

                      We may de-identify data that we collect about you. We may use or share this data with third parties to perform analytics and research, for product development or improvement, and for other compatible purposes or as otherwise permitted by law. We may also permanently anonymize your Personal Data so that it is no longer personal data under relevant laws. After permanent anonymization, you can never be identified, and the data is not traceable to you. We may use or share such anonymized data for statistical analysis, clinical research, demographic analysis, or other similar activities. We may export and process permanently anonymized data in any country in which we or one of our service providers or business partners has operations. We may also combine or aggregate this data with other third-party data that we collect about you.

                      DATA SHARING WITH DELIVERY SERVICE PROVIDERS

                      Before any transfer of personal data to a third country, DTP Solutions will carry out an in-depth assessment to ensure that the level of data protection in the recipient country complies with the standards of the GDPR. 

                      After your order, your delivery data will be shared with our delivery provider (DPD) for the delivery of the products.

                      DATA SHARING FOR INTERNAL USE

                      This data will also be used for reporting and statistical purposes if you have given your consent and will be stored in DTP Solutions’ internal file management system (Google Workspace / Microsoft 365). It may be shared with LifeScan companies via these same platforms.

                      MARKETING 

                      For CRM communications, emails will be sent via Marketing Cloud (Salesforce) only to customers who have given their consent to receive marketing communications.

                      HOW DO WE STORE YOUR DATA 

                      The data we collect is stored on servers at  Siteground Google Servers in London, United Kingdom which guarantee a high level of security. 

                      INTERNAL TRANSFER OF DATA

                      Personal data may be transferred within LifeScan in order to process it. LifeScan will take all steps reasonably necessary to ensure that such processing is carried out in accordance with this Privacy Policy. The user’s consent to this Privacy policy, followed by the submission of this information, constitutes agreement for this transfer.

                      TRANSFER TO THIRD PARTIES

                      For the purposes of the service, we may transfer some of your Data to our subcontractors, some of whom are located outside the European Union or the European Economic Area.

                      If transfers of personal data are made outside the European Union, these transfers will be carried out in accordance with the appropriate legal guarantees and regulations in force, and it will be ensured that they are located in a country considered adequate by the European Union for the protection of Data.

                      If subcontractors are located in the United States, we will ensure that they are subject to the Privacy Shield agreement. If this is not the case, we will ask them to contractually commit to implementing equivalent measures to ensure the protection of your personal data (European Commission standard clauses).

                      HOW LONG WE RETAIN AND HOW WE SECURE YOUR DATA

                      We undertake to retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including any legal, accounting or reporting requirements.

                      Criteria for determining retention periods

                      We determine the length of time we keep your personal data according to the following criteria:

                        • The nature and sensitivity of the data.
                        • The potential risks associated with unauthorized use or disclosure of your data.
                        • The purposes for which we process your data and the possibility of achieving these purposes by other means.
                        • Applicable legal obligations (for example, tax or document retention laws).

                        Specific retention periods

                          • Customer account data: We retain your customer account data for as long as your account remains active. If your account is inactive, we will retain your data for a period of 3 years from the last activity to comply with our legal and compliance obligations.
                          • Transaction data: We retain transaction details for a period of 10 years to meet legal record-keeping and accounting requirements.
                          • Marketing data: We retain your contact information and marketing preferences for 3 years or until you withdraw your consent. If you choose not to receive marketing communications from us, we will keep a record of your unsubscribe request so that we do not send you unwanted communications.
                          • Navigational data and cookies: We retain navigational data and information collected via cookies for a period of 6 months or until you withdraw your consent.

                          Deletion and anonymization

                          At the end of the applicable retention periods, we will delete or anonymize your personal data. If the data is anonymized (i.e. can no longer be associated with an identifiable natural person), we may use it for research or statistical purposes.

                          Users’ rights

                          You have the right to request the deletion or restriction of the use of your personal data. For more information on your rights and how to exercise them, please consult the “YOUR RIGHTS AND CHOICES WITH REGARD TO PRIVACY” section of this privacy policy.

                          SAFETY AND OTHER REGULATORY REPORTING

                          In order to ensure the safety of medical devices, regulators place a legal obligation on manufacturers to report certain complaints and potential adverse events to them.

                          DTP Solutions may share this information with other LifeScan LLC companies in other countries, its service providers or business partners who assist in the maintenance and operation of DTP Solutions complaints database.

                          In some cases, DTP Solutions is obliged to pass on details of complaints and potential adverse events to the device’s legal manufacturer so that they may report the matter to applicable regional or national regulatory bodies, including those that may have different data protection laws than the laws that apply in your country.

                          Where relevant, DTP Solutions enters into European Union standard contractual clauses (or equivalent measures) with the party outside the European Economic Area receiving the personal data. A copy of the relevant standard contractual clauses is available upon request.

                          DTP Solutions processes complaint and adverse event data in order to comply with legal requirements to which it or its business partners are subject. Where DTP Solutions processes health data (which is a special category of data) for these purposes, DTP Solutions does so for reasons of public interest in ensuring high standards of quality and safety of medical devices. Any data provided for complaint and/or adverse event reporting purposes will not be used for direct marketing.

                          If you are a healthcare professional, DTP Solutions may be required, by law or industry codes of practice, to report on or to make public disclosures of certain payments or transfers of value to healthcare professionals (such as consulting fees, travel and other permitted expenses). Where required by local law, we will disclose your identity, your location and the nature and amount of the transfer of value or payment.

                          LINKS TO OTHER SITES

                          When we provide a link to another website or application that is not owned or controlled by DTP Solutions, we are not responsible for how such websites or applications handle your Personal Data. We urge you to read the linked website’s privacy policy. The inclusion of a link to a third-party website or application does not mean that DTP Solutions endorses that website or application.

                          NOTICE FOR EUROPEAN UNION USERS: HOW TO COMPLAIN TO A REGULATOR AND DPO CONTACT DETAILS

                          If you are a European Union citizen or you are accessing any of our Services from within the European Economic Area, you may lodge a complaint with the supervisory authority for your country of residence. Their details can be found here.

                          In accordance with the provisions of the General Data Protection Regulation (GDPR), you, as a user, have the right to lodge a complaint with a competent supervisory authority in the event that you believe that the processing of your personal data constitutes a breach of current data protection regulations.  You have the right to lodge a complaint with the supervisory authority in the country where you reside, work, or in which you believe a breach of the GDPR has occurred.

                          You may contact our Data Protection Officer (“DPO”) by sending an email to admin@dtp-solutions.ie.

                          HOW YOU CAN CONTACT US

                          The company responsible for collection use and disclosure of your Personal Data under this Privacy Policy is:

                          For privacy-related enquiries or complaints, please send an email to the relevant customer service email address in the table above. You can also write to our privacy officer at: DTP Solutions Ltd, Suite A, Elm House, 6 Millennium Park, Osberstown, Naas, Co. Kildare, W91 R2H1 or by sending an email to: admin@dtp-solutions.ie

                          UPDATES TO THIS PRIVACY POLICY

                          This Privacy Policy is subject to periodic revisions to align with best practices and legal requirements. We encourage you to consult it regularly to stay informed of any changes.

                          We may update this Privacy Policy from time to time. To the extent permitted by applicable law, any changes will be effective when we post the revised Privacy Policy on our Services and your continued use of the relevant Service after these changes means that you accept the relevant changes. If the changes are significant, we may provide a more prominent notice to let you know what the changes are. This Privacy Policy was last updated as of the “Last Updated” date shown at the top of this Privacy Policy.olicy was last updated as of the “Last Updated” date shown at the top of this Privacy Policy.