This policy covers children under 13 in the United States
Livongo Health, Inc. describes its collection, use, disclosure and parental consent practices for information provided by children under 13 in the United States. This policy supplements its Privacy Policy and Notice of Privacy Practices and says it accords with COPPA. This saved version is effective January 1, 2020 and was last updated December 17, 2019; it does not establish today’s practices.
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This Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”) and supplements our Privacy Policy and Notice of Privacy Practices.
This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practices in the United States regarding our collection, use, and disclosure, of children’s personal information.
Effective: January 1, 2020
Last Updated: December 17, 2019
Qualifications & exceptions
The assigned version is effective January 1, 2020.
Not stated here
The separate Privacy Policy and Notice of Privacy Practices are not supplied here.
Data Access & Collection · Company commitment
Further enrollment collection pauses until verifiable parental consent
Livongo initially collects basic demographic information during enrollment. If it identifies an individual as a child requiring parental consent under COPPA, it says it stops further collection except for parent or legal guardian contact information until full verifiable parental consent is obtained.
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During enrollment, Livongo will collect basic demographic information about an individual. If an individual is identified as a child and requires parental consent under COPPA, we will cease collecting any further information, other than parental or legal guardian contact information, until we have obtained full verifiable parental consent.
Qualifications & exceptions
The pause applies after identification as a child requiring consent under COPPA; guardian contact information remains collectable.
Cross-references
qualifies (model-proposed): Livongo may receive health, insurance and device information — The enrollment rule pauses further collection for a child requiring COPPA consent until full verifiable parental consent, while the program-data clause describes information Livongo may receive.
After consent, Livongo collects more information from a parent or guardian
Once parental or legal guardian consent is received, Livongo says it collects additional information from the parent or guardian, such as contact and insurance information.
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Once we receive parental or legal guardian consent, we will collect additional information from a parent or legal guardian such as contact and insurance information.
Qualifications & exceptions
Examples include contact and insurance information.
Consent and eligibility precede a child’s program benefits
After consent and confirmation of eligibility, the child receives the enrolled Livongo Program’s benefits. The listed program includes a connected device and app, unlimited strips and lancets, personalized tips and insights, expert coaches, shareable health reports and 24/7 support.
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Supporting quotations
Once we receive consent, and the child is confirmed as eligible for a Livongo Program, the child will being to receive the benefits of the Livongo Program for which the child has enrolled. The Livongo Program includes a connected device and app, unlimited strips and lancets, personalized tips and insights, access to expert coaches, shareable health reports, and 24/7 support.
Qualifications & exceptions
Benefits are for the program in which the child enrolled.
Data Access & Collection · Company practice
Livongo may receive health, insurance and device information
As part of a Livongo Program, Livongo may receive personal information such as height, weight, medical history and insurance information, along with connected device readings, lab results and prescription data. The enrollment consent conditions apply when the child requires parental consent under COPPA.
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Supporting quotations
As part of a Livongo Program, Livongo may receive certain types of personal information (including height, weight, medical history, and insurance information), connected device readings, lab results, and prescription data.
If an individual is identified as a child and requires parental consent under COPPA, we will cease collecting any further information, other than parental or legal guardian contact information, until we have obtained full verifiable parental consent.
Qualifications & exceptions
Receipt is described as part of a Livongo Program, subject to the enrollment consent conditions.
Cross-references
qualified by (model-proposed): Further enrollment collection pauses until verifiable parental consent — The enrollment rule pauses further collection for a child requiring COPPA consent until full verifiable parental consent, while the program-data clause describes information Livongo may receive.
Cookies and identifiers may support analysis and personalization
Livongo may use cookies and other personal or persistent identifiers, including email and IP addresses, to analyze and personalize the Livongo Program experience. This is a stated purpose, not a description of advertising uses.
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Livongo may use cookies and other personal or persistent identifiers, such as email and IP addresses, to analyze and personalize the Livongo Program experience.
Qualifications & exceptions
The stated purposes are analyzing and personalizing the program experience.
Members get unlimited access to Livongo Expert Coaches
Livongo says members have unlimited access to its Expert Coaches, including by phone, email, text or chat.
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Supporting quotations
Livongo members get unlimited access to Livongo Expert Coaches, including through phone, email, text, or chat.
Sharing & Disclosure · User right or choice
A child with full verifiable parent consent can direct a disclosure
The policy describes a child with full verifiable parent consent directing Livongo to disclose the child’s information to another party, such as the child’s doctor. It separately permits disclosures in other listed circumstances, so child direction is not presented as required for every disclosure.
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In addition to instances where a child with full verifiable parent consent has directed Livongo to disclose their information to another party, such as to their doctor, we may also disclose personal information of children in a limited number of circumstances, including:
Qualifications & exceptions
This route requires full verifiable parent consent; the policy lists additional disclosure routes.
Livongo may disclose children’s information for services to Livongo
Among its listed disclosure circumstances, Livongo permits sharing children’s personal information with those it calls “services provides” to provide a service to Livongo. This passage states that service purpose without spelling out the recipients’ further handling terms.
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we may also disclose personal information of children in a limited number of circumstances, including:
With our services provides to provide a service to Livongo.
Qualifications & exceptions
The stated purpose is providing a service to Livongo.
Not stated here
This passage does not specify further recipient handling terms.
Livongo may disclose information where law permits or requires it
The listed circumstances permit disclosure of children’s personal information if permitted or required by law. Examples include law enforcement, court orders or subpoenas, and protecting the security integrity of Livongo Programs. The wording covers permitted disclosures as well as mandatory ones.
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Supporting quotations
we may also disclose personal information of children in a limited number of circumstances, including:
If permitted or required by law, including to law enforcement, in response to a court order or subpoena, or to protect the security integrity of the Livongo Programs.
Qualifications & exceptions
The clause is conditioned on permission or requirement by law.
Separate Livongo policies also determine permitted disclosures
Livongo also permits disclosures of children’s personal information as allowed by its Privacy Policy and Notice of Privacy Practices. Those documents are not supplied in this source, so this children’s policy does not by itself establish the full disclosure rules. The additional permissions are left unspecified here.
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we may also disclose personal information of children in a limited number of circumstances, including:
As permitted by Livongo’s Privacy Policy and Notice of Privacy Practices.
Qualifications & exceptions
The additional permissions depend on the separate Privacy Policy and Notice of Privacy Practices.
Not stated here
The content and limits of those separate disclosure permissions cannot be determined from this source alone.
Verification information is promised secure storage and no other use
Livongo says it works with PRIVO, which it describes as an FTC approved COPPA Safe Harbor with an identity and consent management platform. It says all information collected for verification is stored securely and used for no other purpose. This is specific to verification information; it does not promise the same use limit for all program data. The policy points to a separate PRIVO privacy policy.
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Livongo works with PRIVO. PRIVO is a leading privacy solutions expert as well as an FTC approved COPPA Safe Harbor with an identity and consent management platform. All information collected for verification is stored securely and not used for any other purpose.
Qualifications & exceptions
The secure-storage and purpose limitation applies to information collected for verification.
Not stated here
The linked PRIVO policy is not supplied, and this passage specifies no retention duration.
Data Access & Collection · User right or choice
Parents can refuse further collection from their child at any time
Parents can at any time refuse to allow Livongo to collect further personal information from their child in association with a Livongo Program account.
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At any time, parents can refuse to permit us to collect further personal information from their child in association with a Livongo Program account and can request that we delete from our records the personal information we have collected in connection with that account.
Qualifications & exceptions
The choice concerns collection associated with a Livongo Program account.
Parents may request deletion, which can end the child’s program
Parents may request deletion from Livongo’s records of personal information collected in connection with the child’s account. Livongo warns that a deletion request may lead to termination of the child’s Livongo Program; termination is a possibility rather than an automatic result.
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At any time, parents can refuse to permit us to collect further personal information from their child in association with a Livongo Program account and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination the child’s Livongo Program.
Qualifications & exceptions
The request concerns information connected with the account; program termination is possible.
Not stated here
This passage gives no deletion deadline or retention schedule.
Parents can request access, changes or deletion through Member Support
For an enrolled child, a parent can request access, change or deletion of the personally identifiable information collected from that child by contacting Member Support at (800) 945-4355 or membersupport@livongo.com, 24 hours a day, 365 days a year. The policy also describes parent identity checks before “granting permission to any personal information”; it does not explain that phrase precisely. Deletion requests may terminate the child’s program.
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Where a child has enrolled in a Livongo Program, a parent can request access, change, or deletion of the personally identifiable information that we have collected from their child by contacting Livongo Member Support using any of the methods below 24 hours a day, 365 days a year:
Phone: (800) 945-4355
Email: membersupport@livongo.com
To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting permission to any personal information.
Please keep in mind that a request to delete records may lead to a termination the child’s Livongo Program.
Qualifications & exceptions
Applies where a child has enrolled; parent identity checks and possible program termination on deletion are described.
Not stated here
The wording “granting permission to any personal information” does not specify precisely which action the identity check precedes.
qualified by (model-proposed): Livongo takes reasonable steps to verify a parent’s identity — The parental-controls section describes reasonable parent identity checks before permission concerning personal information; the exact action covered by that phrase remains unclear rather than being silently changed into an access rule.
Written requests should identify the child and give parent contact details
In correspondence such as email or mail, Livongo asks for information that helps identify the child, plus the parent’s email address and telephone number.
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Supporting quotations
In any correspondence such as email or mail, please include information that will help us identify the child as well as the parent’s email address and telephone number.
Qualifications & exceptions
The instruction applies to correspondence such as email or mail.
Security & Safeguards · Company commitment
Livongo takes reasonable steps to verify a parent’s identity
To protect children’s privacy and security, Livongo says it will take reasonable steps to help verify a parent’s identity before “granting permission to any personal information.” In the parental-controls context, that phrase indicates a check before a permission concerning personal information, but its precise object is unclear. The analysis does not replace it with an assumed access or disclosure rule.
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Supporting quotations
To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting permission to any personal information.
Qualifications & exceptions
The promise is to take reasonable steps, for children’s privacy and security.
Not stated here
The source does not specify what “granting permission to any personal information” means or the precise verification method.
Cross-references
qualifies (model-proposed): Parents can request access, changes or deletion through Member Support — The parental-controls section describes reasonable parent identity checks before permission concerning personal information; the exact action covered by that phrase remains unclear rather than being silently changed into an access rule.
Account & Service Control · Procedure
Member Support handles privacy questions and additional policy inquiries
Livongo directs privacy questions and additional children’s-policy inquiries to Member Support by phone at (800) 945-4355 or email at membersupport@livongo.com. Its listed postal contact is Livongo Health, Inc., Attn: Member Support, 444 N. Michigan Ave., Suite 3400, Chicago, IL 60611.
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Supporting quotations
If you have questions or concerns about Livongo’s privacy practices, please call contact our member support line at (800) 945-4355 or membersupport@livongo.com.
Any additional inquiries about this Children’s Online Privacy Policy may be directed to Livongo Member Support as follows:
Phone: (800) 945-4355
Email: membersupport@livongo.com
Address: Livongo Health, Inc.
Attn: Member Support
444 N. Michigan Ave., Suite 3400 Chicago, IL 60611
Legal Rights & Agreement Rules · Company commitment
Livongo reserves amendments and promises notice before material changes
Livongo reserves the right to amend the policy to reflect changes in its privacy practices or the law and asks readers to check back periodically. It says it will provide notice before making a material change. The passage does not specify a notice method or lead time.
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Note: We reserve the right to amend the terms of this policy to reflect changes in our privacy practices or the law. Accordingly, please check back periodically. If we make a material change to this policy, we will provide you with notice before making the changes.
Qualifications & exceptions
Advance notice is promised for material changes.
Not stated here
No notice method or minimum advance period is given in this passage.