Insulet Applicant Privacy Notice

For the United States:

Insulet Corporation

• Address: registered office is in the United States, at 100 Nagog Park, Acton, Massachusetts, 01720.

For the United Kingdom:

Insulet International Limited

• a company incorporated in England and Wales (registered number 10695788 whose registered office is at 1 King Street, 5th Floor, London, W6 9HR, England

For Germany:

Insulet Germany GmbH

• Address: Landsberger Strasse 302, Office 431, 80687 Munich, Germany

For France:

Insulet France SAS

• Address: 3, Boulevard Sébastopol, 75001 Paris, France

For the Netherlands and Belgium

Insulet Netherlands B.V.

• Address: 21 AZ Utrecht, Netherlands

For Portugal

Insulet Portugal, Unipessoal LDA

• Address: Calçada Bento da Rocha Cabral, 1, 1250-047 Lisbon

For Spain

Insulet Spain S.L.

• Address: Paseo de la Castellana Num 53, Planta1, 28046, Madrid

For United Arab Emirates:

Insulet Middle East & Developing Markets

• Address: Unit 807, 8th floor, DSP South Tower, Dubai Science Park, Al Barsha South 2, Dubai, UAE

For Kingdom of Saudi Arabia:

Insulet Middle East & North Africa Regional Headquarters

• Address: Al Olaya Business Center, fifth floor office 52Al Olaya, Riyadh 12244 2478

For Malaysia:

Insulet Malaysia Sdn. Bhd.

• Business: No. 5, Jalan Persiaran Bioteknologi, Kawasan Perindustrian SILC, 79200 Iskandar Puteri, Johor Durul Ta'zim, Malaysia
• Registered Office: Level 13, Menara 1 Sentrum, No. 201, Jalan Tun Sambanthan, Brickfields, Kuala Lumpur, 50470, Malaysia

For Mexico:

Insulet Guadalajara S. de R.L. de C.V.

• Physical Address: Av Adolfo López Mateos Norte 2405, 22nd Floor, Italia Providencia, 44648 Guadalajara, Jalisco, Mexico
• Registered Office: Calle Gabriel Mancera 1041, Colonia del Valle Centro, Benito Juárez, 03100 Ciudad de México, Mexico, Mexico

Insulet Mexico, S. de R.L. de C.V.

• Registered Office: Calle Gabriel Mancera 1041, Colonia del Valle Centro, Benito Juárez, 03100 Ciudad de México, Mexico, Mexico

For Australia:

Insulet Australia Pty Ltd

• Registered Office: Tower 2 Darling Park, Level 16, 201 Sussex Street, Sydney , NSW 2000

We obtain and use your Personal Information in connection with your application. Information we collect, and the purpose for collection includes:

Insulet collects and uses your Personal Information for the purpose of determining your qualifications for current or future employment and reaching a hire decision, to support Insulet’s diversity initiatives as permitted by law, as well as to comply with applicable laws and regulations, such as laws related to the evaluation of those seeking employment, or to defend ourselves in claims under such laws.

Relevant portions of your Personal Information, if you are hired, will also be used to establish a basic employment record. We do not collect or use the Personal Information you submit as a job applicant for purposes unrelated to the hiring and onboarding processes.

Insulet may contact you, using the contact information you have provided, for the purpose of responding to your application for a particular job or jobs. In addition, you may be notified about new jobs matching your preferences and other events and announcements if you provide consent for these notifications.

Most of the Personal Information Insulet obtains about you is collected from your application and resume or curriculum vitae, which is stored on serves located in the United States. We may also collect this type of information from you through other channels and data collected through those channels may be stored on servers in other jurisdictions. We may also collect information about you from third parties (including publicly available sources) in order to:

1. Verify information about your credentials, such as education, qualifications, and prior employment,
2. Follow-up on references that you may provide, and
3. Conduct background checks.

It is Insulet’s policy to collect such information from third parties only with your knowledge and consent. Should Insulet wish to obtain such third-party information about you, and you have not completed an employment application authorizing us to do so, we will contact you and request your authorization to proceed.

If you provide your information through one of our recruitment channels, you will be informed how to access and update that information in that channel. Once your resume is submitted for a specific opening, you will not be able to update the information contained in that copy of your resume. A new resume may be submitted when applying for other positions.

We will only collect, use, process and share your Personal Information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

1. our use of your Personal Information is necessary for our legitimate interest as a commercial organization (for example, our legitimate interests include communicating with you or performing statistical analysis); in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the section Your Rights and Choices, and How to Exercise Them.
2. our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you;
3. where necessary to protect the vital interests of you or another person;
4. our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, for example fulfillment of a court order; or
5. in any other case where you have voluntarily provided your Personal Information and consent to processing for the relevant purposes as described in this notice.

Where the collection or processing is based on your consent, you may withdraw your consent at any time to the extent permitted by applicable law provided that any revocation of your consent will not affect the lawfulness of any processing which has already validly occurred.

Access to your information will be restricted to our corporate affiliates and those Insulet employees and service providers under contract to Insulet who have a need to know the specific information in question in order to enable Insulet to carry out its responsibilities with regard to recruitment or employment law.

Personal Information may also be released to external parties as required by law or legislation, agreements, or by legal process, to our professional advisors (including accountants, auditors and lawyers) as well as to parties to which you have authorized Insulet to release your Personal Information.

Your Information may also be disclosed to governmental entities in compliance with applicable law in the United States and other countries, such as to those agencies authorized to review and enforce equal opportunity laws.

In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business assets or stock, Insulet is likely to disclose your Personal Information to associated entities and their professional advisors, subject to a requirement that such information be used only in accordance with this notice, or as otherwise permitted under an applicable agreement.

Your Personal Information is transferred to and processed in the United States by Insulet and third parties providing services to Insulet, and may also be transferred to other countries if necessary for the application process (e.g., in order to share the data with local hiring managers). Insulet has put in place adequate measures such as standard contractual clauses, to adequately protect cross-border transfers, and requires all of its agents to abide by applicable privacy and data protection requirements in the jurisdictions in which they operate.

Insulet retains your Personal Information only as long as is necessary for evaluation of employment, as well as to comply with applicable laws relating to the evaluation of those seeking employment and/or to defend claims made by them against Insulet. After this time, normally within three years or less, your information is deleted, unless you consent to Insulet retaining your information for a longer period of time.

We are a global organization and transfer personal information to other countries and regions globally, including countries which may not provide for the same level of data protection as is provided in your country such as the United States. Some of these countries are recognized by the European Commission as providing an adequate level of data protection in accordance with EU requirements. For transfers from the EU to countries not recognized as offering an adequate level of data protection we put in place appropriate safeguards, for example, standard contract clauses adopted by the European Commission to ensure such transfers comply with applicable data protection laws.

We have implemented technical and organizational security measures to protect your personal information. These measures are aimed at ensuring the integrity, confidentiality and availability of your personal information and to protect it against unlawful or unauthorized destruction, loss, alteration, use or disclosure, or access. We evaluate and update these measures on a regular basis.

We will retain your personal information during the application process. Once the application process is over, we will retain your personal information for the period of time that enables us to:

• check our records should you apply for another position with us;
• fulfil our legal obligations, including legal retention periods;
• initiate, investigate or defend against legal claims;
• address your questions, requests or complaints.

Where we are allowed to do so by applicable laws, we will retain your personal data for a longer period in our talent pool to contact you for future job opportunities or events. Where legally required, we will ask for your consent. You may withdraw this consent at any time by using the privacy webform or sending an email to [email protected].

If your application is successful, your personal information will form part of your personnel file and will be processed and retained in compliance with the Insulet Employee Privacy Statement which will be provided to you when entering into the employment agreement.

It is important that the Personal Information we hold about you is accurate and up to date. If you become aware that Personal Information we hold is inaccurate or if your Personal Information changes, we ask that you let us know about this promptly, so that appropriate action can be taken. Please note that if you fail to provide certain information when requested, we may not be able to process your application or we may be prevented from complying with our legal obligation.

There may also be cases where you provide us with the Personal Information of others. For example, you may provide contact details about residents for references. When this occurs, we ask that you explain to affected individuals that the Personal Information is being collected for these purposes and that you provide them with a link or copy of this notice if requested.

Insulet is the data controller of the personal information of its job applicants. Whenever you see the following terms in this notice, they have the meaning as defined below:

• “GDPR” means the EU General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as implemented into national UK legislation (the “UK GDPR”), in each case as applicable and incorporating any national laws implementing or supplementing the GDPR.
• “Personal Information” means any information relating to an identified or identifiable individual, including information that can be used to identify, contact or locate an individual. This term encompasses pieces of Personal Information defined as being “Sensitive Personal Information.”
• “Processing” means any action we may take related to your Personal Information, including collection, use, disclosure, handling, storage, transmission, protection, modification, or disposal. When used in this notice, the terms “Process” and “Processed” should be read in line with this definition.
• “Sensitive Personal Information” means (i) any Personal Information defined as being one or more of the Special Categories of Personal Information under the GDPR (including any information concerning or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data for the purpose of uniquely identifying any individual, data concerning health, or data concerning an individual’s sex life or sexual orientation) and/or; (ii) any Personal Information relating to the commission or of criminal offences.

While applicant data is Processed and transferred based upon the reasons described in the Why We Can Process Your Information section, the Personal Information that is retained to maintain the employment records of successful applicants is Processed in accordance with the principles of these programs, as well as the implementation of the principles and requirements of the GDPR. For those entities for which Insulet has determined the need to appoint a Data Protection Officer according to the GDPR, this function is being carred out by a member of Insulet’s Data Protection Office, who can be contacted as described in the How To Contact Us section. You have the right to request from Insulet access to and rectification or erasure of Personal Information or restriction of Processing or to object to Processing as well as a right to data portability. Exercise of these rights is facilitated by using either the Insulet privacy webform or send an email to [email protected]. Please also contact the Global Privacy Office in order to identify the relevant Data Protection Authority, if you wish to get in contact with them.

Processing of Special Categories of Personal Information

Where Insulet collects Sensitive Personal Information, then it will only Process such information where it has an additional legal basis, including:

• where necessary for the purposes of carrying out obligations and exercising specific rights in the field of employment and social security laws;
• to assess working capacity and/or make reasonable adjustments;
• to protect the vital interests of you or another person;
• for the establishment , exercise or defense of legal claims;
• where Processing relates to Personal Information that has been manifestly made public;
• where Processing is necessary for reasons of substantial public interest, including for example where:
  • Processing of Personal Information relates to race or ethnicity is necessary for equalities monitoring purposes; and/or
  • Processing of Personal Information relates to criminal offences is necessary to prevent or detect unlawful acts, or to enable compliance with applicable regulatory requirements.

In limited circumstances, we may approach you for your explicit written consent to allow us to Process Sensitive Personal Information. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of any employment with us that you agree to any request for consent from us.

California law provides Insulet job applicants who are residents of the U.S. state of California with specific privacy rights. You are entitled to receive notice about the categories of Personal Information Insulet has, in the preceding 12 months, collected about you, and for what business purposes that information has been used, how long it is retained, and to which third parties it has been disclosed. This information is provided in this notice. You have the right to request from Insulet access to, correction, and deletion of your Personal Information, as well as the right to data portability. These rights can be exercised by using either the Insulet privacy webform or send an email to [email protected]. Please note that Insulet does not sell job applicant Personal Information, share your information for the purposes of behavioral advertising, or re-identify de-identified personal information. Additionally, we do not offer substantive financial incentives for collection or sale of your Personal Information or use it for the purposes of purely automated decision-making with a legal or similar significant impact. Furthermore, we process Sensitive Personal Information with your consent or as permitted by law. We will also not discriminate against if you exercise your rights under California law.

If Insulet uses biometric data in its hiring process, for Malaysia, Personal Sensitive Data now includes biometric data as of June 1, 2025. Insulet bases on explicit consent the processing of biometrics for applicants in Malaysia.

Upon request, this notice can be made available in alternative formats, such as large print or a paper copy. Please contact us and an alternative format will be provided to you so you can access the information in this notice.

For those European entities for which Insulet has determined the requirement to appoint a Data Protection Officer, Insulet’s Global Privacy Office performs all of the duties required of a Data Protection Officer specified by the General Data Protection Regulation (GDPR) and/or local law and can be contacted as described under Contact Us.

For those Malaysian entities for which Insulet has determined the requirement to appoint a Data Protection Officer, Insulet’s Global Privacy Office performs all of the duties required of a Data Protection Officer specified by the Personal Data Protection (Amendment) Act of 2024 and/or local law and can be contacted as described under Contact Us.

You have the right to request, from Insulet, access to and rectification or erasure of Personal Information or restriction of processing or to object to processing as well as a right to data portability. You may have different choices and privacy rights depending on the jurisdiction in which you live. Exercise of these rights is facilitated by using the Insulet privacy webform or send an email to [email protected].

The site you are using to submit your application may contain links to other websites. Insulet is not responsible for the way in which these third parties handle your personal information. We advise you to read the privacy statement of the third parties when you visit such websites in order to understand how your personal information is handled.

If you wish to exercise your privacy rights, have questions about Insulet’s processing of your Personal Information or wish to file a complaint:

Submit your request using the Insulet privacy webform or send an email to [email protected]. For EU applicants, if you wish to contact the DPO to be informed of your rights, please send an email at [email protected]

While we process your Personal Information, we ask that you check the terms of this notice for updates periodically. Insulet reserves the right to amend this notice in order to reflect changes in processing activities or legal requirements. For previous versions of this notice, please submit your request using the Insulet privacy webform or send an email to [email protected].