Effective/Updated as of February 20, 2025.
Your privacy is important to Senseonics, Incorporated ("Senseonics","we","us" or "our") and we recognize the
responsibility you entrust us with when providing your personal information. This Privacy Notice describes how
Senseonics handles personal information that we collect through our digital properties that link to this Privacy
Notice, including our website (https://www.senseonics.com/), as well
as through social media, our marketing activities, our investor events, our live events and other activities
described in this Privacy Notice (collectively, the "Platforms").
Senseonics provides additional or supplemental
privacy policies to individuals for specific products or services that we offer at the time we collect personal
information. For more information about how we process your personal information when you utilize our products,
services, and tools, please consult our Product Privacy Notice.
Below we also include additional information for certain states in the US, including for California residents subject
to the California Consumer Privacy Act, amended by the California Privacy Rights Act. If you are located in the
European Economic Area (EEA) or Switzerland (which we refer to as "Europe," and
"European" should be understood accordingly), see the Notice to European users below.
Index
Personal information we collect
How we use your personal information
How we share your personal information
Your choices
Other sites and services
Security
International data transfer
Children
Retention
Changes to this Privacy Notice
How to contact us
California and other US State Rights
Notice to European users
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Platforms or otherwise includes:
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Contact data such as your first and last name, salutation, email address, postal address, professional title and company
name, and phone number.
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Communications that we exchange with you, including when you contact us through the Platforms.
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Marketing data such as your preferences for receiving our marketing communications and details about your engagement with
them.
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Job application data such as professional credentials and skills, educational and work history, LinkedIn profile page, personal
website, authorization to work in the U.S., immigration status and other information that may be included on
a resume or curriculum vitae as well as in a cover letter. This may also include diversity information that
you voluntarily provide.
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Other data not specifically listed here, which we will use as described in this Privacy Notice or as otherwise disclosed
at the time of collection.
Cookies and similar technologies some of the data collection is facilitated by "strictly necessary" cookies, which are small text files that websites
store on user devices to enable our website to provide the function you have requested, such as by helping to ensure
that the content of a page loads quickly and effectively.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
To manage our relationship with you. We may use your personal information to:
- Provide, operate, maintain and improve the Platforms and our business.
- Personalize the Platforms, including remembering your selections and preferences as you navigate the Platforms.
- Provide information about the Platforms or other products and services.
- Communicate with you about the Platforms, including by sending announcements, updates, security alerts, and support and administrative messages.
- Understand your needs and interests, and personalize your experience with the Platforms and our communications.
- Provide support for the Platforms, and respond to your requests, questions and feedback.
Platform improvement and analytics We may use your personal information to analyze and improve the Platforms, improve the rest of our business, help us
understand user activity on the Platforms, and to develop new products and services.
Marketing. We and our service providers may collect and use your personal information for marketing purposes. For example, we
may send you direct marketing communications. You may opt-out of marketing-related communications by contacting us
at [email protected]. Please note that if you choose to
opt-out of marketing-related communications, you may continue to receive service-related and other non-marketing
communications.
Recruiting and Job Applications. We may use personal information, such as data submitted to us in a job application, to facilitate our recruitment
activities and process job applications, such as by evaluating a candidate for a job, and monitoring recruitment
statistics.
Compliance and protection. We may use your personal information to:
- Comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests
from government authorities.
- Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal
claims).
- Audit our internal processes for compliance with legal and contractual requirements or our internal policies.
- Enforce the terms and conditions that govern the Platforms.
- Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity,
including cyberattacks and identity theft.
Use for New Purposes. We may use your personal information for reasons not described in this Privacy Notice where permitted by law and the
reason is compatible with the purpose for which we collected it.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Notice
or at the time of collection.
Service providers. Third parties that provide services on our behalf or help us operate the Platforms or our business (such as
videoconferencing, hosting, information technology, customer support, email delivery, marketing, consumer research,
and website analytics).
Partners.
We may sometimes share your personal information with partners or
enable partners to collect information directly via our Platforms.
Professional advisors.
Professional advisors, such as lawyers, auditors, bankers and insurers,
where necessary in the course of the professional services that they
render to us.
Authorities and others.
Where required by applicable law, we may also need to transfer your
personal information to law enforcement, government authorities, and
private parties, as we believe in good faith to be necessary or
appropriate for the compliance and protection purposes described
above.
Business transferees.
We may disclose personal information in the context of actual or
prospective business transactions (e.g., investments in Senseonics,
financing of Senseonics, public stock offerings, or the sale, transfer
or merger of all or part of our business, assets or shares). For
example, we may need to share certain personal information with
prospective counterparties and their advisers. We may also disclose your
personal information to acquirers and other relevant participants in
business transactions (or negotiations of or due diligence for such
transactions) involving a corporate divestiture, merger, consolidation,
acquisition, reorganization, sale or other disposition of all or any
portion of the business or assets of, or equity interests in, Senseonics
or our affiliates (including, in connection with a bankruptcy or similar
proceedings).
Please keep in mind that whenever you voluntarily make your personal
information available for viewing by third parties or the public on or
through our Platforms, that information can be seen, collected and used by
others. We are not responsible for any use of such information by others.
Other Sites and Services
The Platforms may contain links to
websites, mobile applications, and other online services operated by third
parties. In addition, our content may be integrated into web pages or
other online services that are not associated with us. These links and
integrations are not an endorsement of, or representation that we are
affiliated with, any third party. We do not control websites, mobile
applications or online services operated by third parties, and we are not
responsible for their actions. We encourage you to read the privacy
policies of the other websites, mobile applications and online services
you use.
Security
We employ a number of technical,
organizational and physical safeguards designed to protect the personal
information we collect. However, security risk is inherent in all internet
and information technologies, and we cannot guarantee the security of your
personal information.
International data transfer
We are headquartered in the United States
and may use service providers that operate in other countries. Your
personal information may be transferred from or to the United States or
other locations where privacy laws may not be as protective as those in
your state, province, or country.
If you are located in Europe, see the Notice to European users below.
Children
The Platforms is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child
from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we
learn that we have collected personal information through the Platforms from a child without the consent of the
child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the
information.
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including
for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements, to establish or defend
legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal data, we consider the following criteria:
- our legal obligations to retain the personal data under applicable laws.
- applicable legal holding and/or limitation periods for the establishment, exercise or defense of any potential
legal claims.
When we no longer require the personal data we have collected about you, we will either delete or irreversibly
anonymize it or, if this is not possible (for example, because your personal data has been stored in backup
archives), then we will securely store your personal data and isolate it from any further processing until deletion
is possible. If we anonymize your personal data (so that it can no longer be associated with you), we may use this
information indefinitely without further notice to you.
Changes to this Privacy Notice
We reserve the right to modify this Privacy Notice at any time. If we make material changes to this Privacy Notice,
we will notify you by updating the date of this Privacy Notice and posting it on the Platforms or other appropriate
means. Any modifications to this Privacy Notice will be effective upon our posting the modified version (or as
otherwise indicated at the time of posting). In all cases, your use of the Platforms after the effective date of any
modified Privacy Notice indicates your acknowledgment of the content of the modified Privacy Notice.
Email: [email protected]
Mail: Senseonics, Incorporated
Data Protection Officer
Senseonics, Incorporated
20451 Seneca Meadows Parkway
Germantown, MD 20876
USA
California and other US State Residents
We collect information about individuals in a variety of ways. This section only applies to residents of certain US
States, including California, whose personal information is subject to the California Consumer Privacy Act, as
amended by the California Privacy Rights Act (“CPRA”) or the equivalent laws in certain other US States. This
section does not always apply, and does not apply to information we collect about employees and job applicants. If
you would like to know if the rights apply to you, please contact: [email protected].
Below is a summary of the personal information we may collect from you when you access or use our Platforms, and the
categories of third parties with whom we may share consumer personal information.
| Categories of Personal Information We Collect |
Categories of Third Parties With Whom We May Disclose Personal Information for a Business Purpose |
| Identifiers such as real name, postal address, country of origin, IP address, email address, account name,
date of birth, other similar identifiers. |
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Software, development, maintenance, data storage, and web analytics service providers; service providers and
distributors involved in providing the Platforms
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Senseonics and affiliated parties
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Third party applications (if applicable)
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Law enforcement or other authorities for legal compliance
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Entities involved in a corporate reorganization, merger, or acquisition and their representatives
|
| Characteristics of protected classifications under California, other US State Privacy Laws, or Federal Law,
such as age and gender. |
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Software, development, maintenance, data storage, and web analytics service providers; service providers and
distributors involved in providing the Platforms
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Senseonics and affiliated parties
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Health care professionals
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Third party applications (if applicable)
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Entities involved in a corporate reorganization, merger, or acquisition and their representatives
|
| Commercial information, including products or services purchased, obtained, or considered, or other
purchasing or consumer history. |
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Software, development, maintenance, data storage, and web analytics service providers; service providers and
distributors involved in providing the Platforms
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Senseonics and affiliated parties
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Third party applications (if applicable)
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Entities involved in a corporate reorganization, merger, or acquisition and their representatives
|
| Categories of Personal Information We Collect |
Categories of Third Parties With Whom We May Disclose Personal Information for a Business Purpose |
|
Internet or other electronic network activity information, including status/HTTP status code, operating
system, browsing software version, device ID, browsing history, search history, and interactions with
websites, applications, or advertisements.
|
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Software, development, maintenance, data storage, and web analytics service providers; service providers and
distributors involved in providing the Platforms
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Entities involved in a corporate reorganization, merger, or acquisition and their representatives
|
|
Geolocation data, such as your precise or approximate location derived from information from your mobile
device.
|
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Software, development, maintenance, data storage, and web analytics service providers; service providers and
distributors involved in providing the Platforms
|
|
Inferences drawn from collected information to create a profile about a consumer reflecting preferences,
characteristics, psychological trends, behavior, attitudes, intelligence, abilities, and aptitudes.
|
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Software, development, maintenance, data storage, and web analytics service providers; service providers and
distributors involved in providing the Platforms
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Senseonics and affiliated parties
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Third party applications (if applicable)
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Entities involved in a corporate reorganization, merger, or acquisition and their representatives
|
How Long We Keep Personal Information: We keep your personal
information for as long as needed or permitted. We may remove personal
information for inactive accounts from our database, subject to any
applicable legal or regulatory obligations. Similarly, we may delete
personal information at any time and without providing a reason.
Your Rights: Subject to certain legal limitations and
applicable exceptions,
residents of certain US States, including California, may exercise
the following rights via mail at: [email protected].
Right to Know. You have the right to request information about the categories of
personal information we have collected about you, the categories of
sources from which we collected the personal information, the
purposes for collecting the personal information, and the categories
of third parties with whom we have shared your personal information
(“Categories Report”). You may also request information about the
specific pieces of personal information we have collected about you
(“Specific Pieces Report”).
Right to Delete. You have the right to request that we delete personal information
that we have collected from you.
Right to Opt Out.
To the extent we share your personal information for
marketing
purposes, you may contact us at [email protected] to request
that we stop doing so. We do not sell any personal
information (including information about minors).
Right to data portability. You have the right to request your data in a readily useable format
that allows you to transmit the information from one company to
another.
Verification: In order to exercise your rights, we will need to
obtain information to verify your identity. If you are submitting a
request on behalf of a household, we will need to verify each member
of the household in the manner set forth in this section. For a
Specific Pieces Report, we will request personal information
sufficient to verify your identity to a reasonably high degree of
certainty and seek a signed declaration, under penalty of perjury,
that you are who you say you are.
Authorized Agents: If you are an authorized agent, we will
request written and signed authorization from the consumer and will
seek to verify the consumer as described above, or we will accept a
legal Power of Attorney under the California Probate Code (or
equivalent law). At a minimum, we will require evidence of your (the
agent’s) identity (via passport or driver’s license submission), proof
of registration with the California Secretary of State (or State
equivalent), and at least one of the following proof of your legal
authority to act on the behalf of the individual who is the subject of
this request:
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Written authorization signed by the consumer,
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Certified copy of a Power of Attorney granted under Probate Code,
or legal equivalent, or
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Evidence of parental responsibility.
Timing: We will respond to Requests to Delete and Requests
to Access within 45 days unless we need more time in which case we
will notify you and may take up to 90 days total to respond to
your request.
Notice to European users
The information provided in this “Notice to European users”
section applies only to individuals in the European Economic Area
(“EEA”) and Switzerland (hereafter collectively referred to
as “Europe” as defined at the top of this Privacy Notice).
Personal information.
References to “personal information” in this Privacy Notice are
equivalent to “personal data” governed by European data
protection legislation – i.e., any information relating to an
identified or identifiable natural person. It does not include
‘anonymous data’ (i.e., information where the identity of
individual has been permanently removed).
Controller.
Senseonics, Incorporated is the controller of your personal
information covered by this Privacy Notice for purposes of
European data protection legislation (i.e., the General Data
Protection Regulation (“GDPR”) and the Swiss New Federal Act on
Data Protection (“nFADP”)).
EU Representative.
Senseonics, Incorporated has appointed European Data Protection
Office (EDPO) as its GDPR Representative in the EU. You can
contact EDPO:
by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
Representative in Switzerland. Our Swiss representative appointed under the nFADP is EDPO
Switzerland. You can contact EDPO Switzerland regarding matters
pertaining to the nFADP:
by using EDPO Switzerland’s online request form:
https://edpo.com/swiss-data-request/
by writing to EDPO Switzerland at Rue de Lausanne 37, 1201 Geneva,
Switzerland
Data Protection Officer.
Our data protection officer can be contacted at:
[email protected]
Or by writing to:
Senseonics, Incorporated
Data Protection Officer
Senseonics, Incorporated
20451 Seneca Meadows Parkway
Germantown, MD 20876
USA
Legal bases for processing.
In respect of each of the purposes for which we use your personal
information, the European data protection legislation requires us to
ensure that we have a legal base for that use. The legal bases of our
processing of your personal information as described in this Privacy
Notice will depend on the type of personal information and the specific
context in which we process it.
However, the legal bases we typically rely on are set
out in the table
below. If you have questions about the legal basis of how we process
your personal information, contact us at [email protected].
|
Processing purpose
Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.
|
Categories of personal information involved
Details regarding the categories of personal information listed below are provided in the section above titled “Personal
information we collect”.
|
Legal basis
|
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To manage our relationship with you: We need to process your personal information to operate the Platforms, including responding to your requests or inquiries, providing you with access to content or information you requested, allow you to participate in investor events etc.
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- Contact data
- Communications data
- Other data
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Processing is necessary to perform the contract governing our provision of our Platforms or to take steps that you request prior to signing up for the Platforms.
|
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To manage our recruiting and process job applications: We may need to process your personal information to process your job application.
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- Contact data
- Job application data
- Communications data
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In these scenarios, the processing of the personal information you voluntarily provide to us is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the services.
|
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Platforms improvement and analytics: We may use your personal information for Platforms improvement and analytics purposes, including to analyze and improve the Platforms and our business.
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Any and all data types relevant in the circumstances
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These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you.
|
|
We may need to process your personal information for additional purposes, such as:
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To ensure access and maintenance of the Platforms, and to ensure
their proper functioning
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For compliance, fraud prevention and safety
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For sharing your personal information with third parties as
described in this Privacy Notice
-
To disclose your personal information to a prospective or actual
purchaser or seller in the context of a merger, acquisition or
other reorganization or sale of our business or assets.
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For the collection of statistical information about the use of
the Platforms
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To protect our interests as a company, for different purposes,
such as:
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Enforcement of the Terms of Platforms
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Assess claims that any content violates the rights of
third-parties
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Establishment or exercise our legal rights or defending against legal claims
|
- Contact data
- Communications data
- Marketing data
- Other data
|
We rely on our legitimate interests to process your personal information when performing these processing activities. We do not use your personal information for these purposes where our interests are overridden by the impact on you.
|
|
For marketing and advertising purposes:
We and our third-party advertising partners may collect and use
your personal information for marketing and advertising
purposes.
|
-
Contact data
-
Communications data
-
Marketing data
|
Processing is based on your consent where that consent is required
by applicable law. Where such consent is not required by applicable
law, we process your personal information for these purposes based on our legitimate interests in promoting our business.
|
|
Compliance with legal obligations and protection purposes:
We are subject to certain legal obligations that may oblige us to
disclose your personal information to courts, law enforcement or
regulatory authorities.
|
Any and all data types relevant in the circumstances
|
Processing is necessary to comply with our legal obligations.
Where compliance with law is not applicable, we and any relevant
third parties have a legitimate interest in participating in,
supporting, and following legal process and requests, including
through co-operation with authorities. We and any relevant third
parties may also have a legitimate interest of ensuring the
protection, maintenance, and enforcement of our and their rights, property, and/or safety.
|
|
Further uses:
We may use your personal information for reasons not described in
this Privacy Notice.
|
Any and all data types relevant in the circumstances
|
The original legal basis relied upon, if the relevant further use is
compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.
|
Your rights. Subject to certain exemptions, and in some cases
dependent upon the
processing activity we are undertaking, you may have the following
rights under data protection laws:
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Right of access:
You have the right to ask us for copies of your personal
information.
-
Right to rectification:
You have the right to ask us to rectify personal information you
think is inaccurate. You also have the right to ask us to complete
information you think is incomplete.
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Right to erasure:You have the right to ask us to erase your
personal information
in certain circumstances.
-
Right to restriction of processing: You have the right to ask
us to restrict the processing of your
personal information in certain circumstances.
-
Right to object to processing: You have the right to object
to the processing of your personal
information in certain circumstances.
-
Right to data portability:
You have the right to ask that we transfer the personal information
you gave us to another organization, or to you, in certain
circumstances.
-
Right to withdraw consent at any time:
Where we are relying on consent to process your personal data, you
have the right to withdraw your consent at any time. However, this
will not affect the lawfulness of any processing carried out before
you withdraw your consent.
-
Right to Lodge a Complaint with a Supervisory Authority:
You may lodge a complaint with your local supervisory authority for
data protection if you are not satisfied with our response to a
request you make, or how we process your personal information. To do
this, you may contact us or submit a complaint to the supervisory
authority in your jurisdiction:
-
For individuals in the EEA – the contact information for the
supervisory authority in your place of residence can be found
here: https://edpb.europa.eu/about-edpb/board/members_en
-
For individuals in Switzerland – the contact information for the
Swiss supervisory authority is below:
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter
Feldeggweg 1
CH - 3003 Bern
However, we encourage you to first contact us.
Exercising These Rights.You may submit these requests by email to
[email protected]
or our postal address provided above. We may ask you for additional
information to confirm your identity and for security purposes, before
disclosing the personal data requested to you. Whether or not we are
required to fulfill any request you make will depend on a number of
factors (e.g., why and how we are processing your personal information),
if we reject any request you may make (whether in whole or in part) we
will let you know our grounds for doing so at the time, subject to any
legal restrictions. We reserve the right to charge a fee where permitted
by law, for instance if your request is manifestly unfounded or
excessive.
Cross-border data transfer. We may, where permitted or required by applicable law or regulation,
transfer your personal data to recipients outside of your country. In
such circumstances, the processing of your personal data will involve a
transfer of your personal data outside of your country where privacy
laws may not be as protective as those in your country. Where we
transfer your personal data outside your country and we are legally
required to implement a transfer mechanism, we will take steps to
transfer your personal data in accordance with applicable law.
Senseonics may transfer your personal data to the following countries:
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Germany (Switzerland (pursuant to Swiss-EU adequacy decision));
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U.S (transfer mechanism: EU Standard Contractual Clauses).
You may contact us in writing by one of the methods set out under “Contact
us” above if you would like further information on the specific mechanism
that we use when transferring your personal data outside of Europe.