Insulet's User Generated Content - Privacy Policy

Thank you for showing interest in the social media accounts of Insulet [specify entity], [address] and its affiliates ("Insulet", "we", "us"). This privacy policy apply to Insulet's use of user generated content on social media
[1] [ED2]

Privacy policy content:

What is this privacy policy about?
What personal data we collect
Why we process your personal data
Processing personal data of minors and legal guardians
Sharing of your personal data
How to exercise your rights
data retention
Contact details
Changes to this privacy

Privacy policy

1. WHAT IS THIS PRIVACY POLICY ABOUT?

This privacy policy describes how the Insulet entity in your country of residence and its affiliates collects and processes personal data of social media users and of legal guardian’s of minors when the social media user tags Insulet in their posts, and/or the social media user or legal guardian consent to the use of content on social media, and the rights and options you have to control your data.
References to "you", "content" and "minor" shall have the same meaning as in our Terms.

2. WHAT PERSONAL DATA WE COLLECT

Personal data is all information that identifies you directly or in combination with other information. The personal data we process include:
- the content you post in which you tag Insulet;
- your questions, queries, or comments directed to Insulet on social media;
- your social media account name;
- information that is publicly available on your social media profile; and
- information your legal guardian has provided about you if you are <18 years old, if applicable.

3. WHY WE PROCESS YOUR PERSONAL DATA

We use your personal data for the following purposes:
- publishing your content on our social media accounts, to provide information to social media users on our products and services and promote them, based on your consent;
- assessing whether your content that you manifestly made public is relevant for Insulet and reflects the use of and experience with Insulet's products and services to provide information to social media users on our products and services and promote them, based on our legitimate business interest to inform the public and market our products and services;
- verifying whether your public social media profile corresponds with the values that Insulet stands for as a company, based on our legitimate business interest to promote our products and services and protect our image and values;
- replying to your questions, queries, and comments on social media, based on our legitimate business interest to interact with you and handle your questions and complaints;
- contacting you to train you on the use of our products and services, based on our legitimate interest to ensure safe and authorized use of our products and services;
- responding to requests or queries of, or reporting to competent public authorities, based on a legal obligation we are subject to or based on our legitimate interest to cooperate with public authorities in cases where we believe this is necessary; and
- protecting our rights and property, or those of third parties, for example to investigate unauthorized use of content, based on our legitimate business interest to safeguard our assets and those of related third parties.
You may withdraw your consent to our use of your content at any time by contacting us via our social media account on which your content is displayed. To verify your identity, we ask you to contact us via your social media account. Subsequently, Insulet will remove the post with your content from its social media account. Your withdrawal of consent shall not affect the lawfulness of our processing of your content before the withdrawal of your consent.
Insulet does not control and is not responsible or liable for use of your content by third parties, outside our own social media accounts, or outside the social media platform. We cannot remove your content from such other location. If you wish to remove your content from other places than our social media account, please contact the publisher of your content or the social media platform it is hosted on.

4. PROCESSING PERSONAL DATA OF MINORS AND LEGAL GUARDIANS

We may process personal data of minors, in the event they share content that is of interest to us. The personal data we collect and the purposes for which we use it are explained in sections 10-11 of this privacy policy. As explained in section 2 of the Terms, we only use content of minors and process personal data of minors displayed on such content with the consent of the legal guardian. We will process such data in accordance with the Terms and this privacy policy.
We process the legal guardian’s personal data in accordance with sections 10 and 12-17 of this privacy policy. In the context of our processing of the legal guardian’s personal data, references in this privacy policy to "you" shall refer to the legal guardian, "your personal data" shall refer to personal data of the legal guardian, "your content" shall refer to the legal guardian’s minor’s content, and "your consent" shall refer to consent provided by the legal guardian.
We process the following personal data of the legal guardian:
- contact details, such as name and e-mail address; and
- any information shared by the legal guardian in the context of questions, queries, or comments.
We use the legal guardian’s personal data for the following purposes:
- sending the legal guardian an email with the Participant Release Form to request consent for the processing of the minor’s content, based on our legitimate interest to obtain consent for sharing content that we use to inform the public and market our products and services;
- verifying in our systems whether the legal guardian is registered as such for the relevant minor, based on our legitimate interest to authenticate the legal guardian;
- replying to the legal guardian’s questions, queries, and comments, based on our legitimate business interest to interact with the legal guardian and handle their questions and complaints;
- contacting the legal guardian to train them on their minor’s use of our products and services, based on our legitimate interest to ensure safe and authorized use of our products and services;
- responding to requests or queries of, or reporting to competent public authorities, based on a legal obligation we are subject to or based on our legitimate interest to cooperate with public authorities in cases where we believe this is necessary; and
- protecting our rights and property, or those of third parties, for example to investigate unauthorized use of content, based on our legitimate business interest to safeguard our assets and those of related third parties.

5. SHARING OF YOUR PERSONAL DATA

We share your personal data with the following third parties:
- social media platforms: we publish your content on the social media platform on which you already published your content yourself;
- companies of the Insulet group: we share your personal data with group companies to e.g. monitor our social media posts, reply to your queries and requests, monitor safe and authorized use of our products and services, verify the identity of the legal guardian providing consent for sharing of content, and to ensure the security of our websites and services;
- service providers: we share your personal data with our third party service providers, for instance service providers that help us with our social media presence; and
- public authorities: we share your personal data with authorities to the extent this is relevant. For example, with supervisory authorities, courts and public bodies, to the extent this is necessary to fulfil a legal obligation or to prosecute criminal offences and fraud. We may also transfer personal data to authorities to protect our rights and property, or the rights and property of third parties.
The third parties which we share data with may be located outside the European Economic Area, Switzerland or the United Kingdom, for example our group companies. These third parties may be located in countries that have a lower legal protection level for personal data than applicable in the European Economic Area, Switzerland or the United Kingdom. We will only provide your personal data to third parties that handle your personal data confidentially and provide appropriate protection in line with European standards, so that the personal data are protected appropriately (e.g. by concluding standard contractual clauses for the transfer of personal data to third countries as approved by the European Commission, or the governments of Switzerland or the United Kingdom, as applicable).
If you have questions about the international transfer of your personal data or the appropriate safeguards that we have taken to protect your personal data, please send an email to [email protected].

6. HOW TO EXERCISE YOUR RIGHTS

We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate or outdated.
If provided under applicable laws, you may ask us to:
- access your personal data;
- rectify your personal data if such data is inaccurate or outdated;
- erase your personal data;
- restrict the processing of your personal data;
- port your personal data to another party;
- object to our use of your personal data; and
- withdraw your consent, if the processing is based on your consent.
In certain situations, we may not be in a position to fully comply with your request. In that case we will inform you about this.
You can exercise these rights by contacting us from your social media account on our social media account on which we used your content. Please note that we will not link your social media account and related content to your Omnipod account. For this reason, you cannot exercise your privacy rights regarding your personal data in your social media account via your contact details in your Omnipod account, and vice versa, as we will not be able to identify you.
We are committed to handling your queries and complaints the best we can. You may also file a complaint with your local data protection authority.

7. DATA RETENTION

We will retain your contact details and other information you provide to us when reaching out to us no longer than necessary to reply to your questions, comments and queries. Furthermore, we retain the content we use based on your consent for a period of 4 years.
In some cases, we will need to retain your personal data for a longer period than necessary for the aforementioned purposes, for instance to fulfil our legal obligations or to bring, investigate or defend legal claims.

8. CONTACT DETAILS

If you have any questions, comments, suggestions or complaints about this privacy policy or the way in which we use your personal data, please contact the office of the data protection officer via email at: [email protected].

9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend this privacy policy from time to time. We therefore advise you to consult our website on a regular basis so that you are aware of any changes. We will take reasonable steps to inform you of changes that will have a substantial impact on your rights.

Version: 31 October 2022