Insulet (Omnipod) Privacy Policy

In order to make our Services available to you, we collect personal information that identifies or could identify you (directly or indirectly), relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you. This information is known as “Personal Information."

The Personal Information we collect can include:

• Personal details, like your name and date of birth
• The username you use on our Services
• Contact information, like your mailing address, email, and phone number
• Details of how you access our Services, like your Internet Protocol address (IP address) or information that identifies the device you use
• Health Information, like information that may reveal your past, present or future physical or mental health condition or status, and limited health insurance information . For more details about the Health Information we collected, please navigate to the Consumer Health Data Privacy Policy section of this policy. Residents of Washington and certain other U.S. states may have additional rights pertaining to how we process their Health information, and these consumers can find out more by reading our Consumer Health Data Privacy Policy section of this Privacy Policy.

You can learn more about the types of Personal Information we may collect and how we use it below.

This Privacy Policy only applies to the Personal Information you share with us while using our Services and does NOT apply to

• Personal Information collected outside of our Services
• Information that does not identify you or that we have deidentified. We can use this information for any purpose. To the extent we deidentify any data originally based on Personal Information, we will maintain and use such data only in deidentified form and will not attempt to reidentify the data.

The Privacy Policy also does not apply to any Personal Health Information (“PHI”). For information regarding our policies with respect to PHI, please see our HIPAA Privacy Notice. Lastly, You may also have additional rights depending on where you live. If you are a health care professional or business contact your personal data may be collected or processed in additional ways. We implore you to look at the relevant sections below for more details. Additionally, residents of Washington and certain other U.S. states can find out more about we handle consumer health data by taking a look at our Consumer Health Data Privacy Policy section of this Privacy Policy.

Privacy is a fundamental part of life and it’s very important to us that you understand how we handle your Personal Information before you share it with us.

We strongly encourage you to carefully read this Privacy Policy before you use any of our Services as you agree to this Privacy Policy simply by installing, using, registering, participating, or otherwise accessing our Services. This means you agree to how we collect, process, use, and share your Personal Information as described below just by taking advantage of our Services available to you.

Are our Services appropriate for a child younger than the age of 18? Our Services are primarily made for adults. This means that you shouldn’t use, submit or post any information to our Services if you are under the age of 18 without your parent or legal guardian’s consent. If you have reason to believe that someone under the age of 18 has given us Personal Information without permission from their parent or guardian, please let us know so we can address the situation.

If you are a resident of Washington, Nevada, or other certain U.S. States who’d like more information on how we process your health data in addition to the ways described in this Privacy Policy, please read the expandable section later below titled “Consumer Health Data Privacy Policy”

If you are a heath care professional (HCP) or business contact. Please read through the expandable section later below titled “Health Care Professionals (HCPs) & Business Contacts” to learn more about how your personal data is processed in addition to what is described in this Privacy Policy.

We will only use and share your Personal Information as explained in this Privacy Policy or with your specific consent.

The Personal Information we collect can include:

• Information you provide directly. We collect Personal Information when you choose to provide it, such as when you enter Personal Information on our websites or download, register, and otherwise access an App. If you contact us, we can also keep a record of that communication. You can use some parts of the Services without sharing certain Personal Information with us, but this might mean you won’t be able to fully access our Services.
• Information we collect automatically. We may also collect Personal Information automatically when you use our Services. For example, when you visit our websites, we collect your IP address to help let you access the website. We also use cookies and similar tools, which you can learn more about below.
• Information we collect from Third Parties. We may also obtain certain Personal Information from other organizations. For example, we obtain certain Personal Information stored in a data management platform you use if you tell them to share it with us.
• Health Information. Certain information we collect, such as information about your use of Insulet products or services and product training information, may reveal information about your past, present, or future physical or mental health condition or status, including your diabetes condition and treatment.

You also agree that we can transfer this information from your location to our offices, servers, and trusted partners as described in this Privacy Policy.

We use various technologies to operate and make our Services available, such as “cookies” and similar tools. A cookie is a small piece of data stored on your computer or mobile device (e.g., phone, tablet) by an internet browser that can be used to identify you and the computer or mobile device you use. We may also use similar tools, like web beacons, pixel tags, or SDKs that work like cookies and are used for similar purposes.

Cookies and similar tools are generally used to help organizations understand how people use a website, personalize user experiences and display more relevant ads, and better serve users. We use cookies to make your experience online better – by understanding how you use our Services, personalizing your online experience, and improving our Services for all of our users.

Want to know more or change your preferences? Check out Our Cookie Policy at our website.

We collect your Personal Information to:

• Share information with you that we think you will be interested in
• Make our Services available to you
• Personalize your experience online and provide you with more relevant information and advertising
• Analyze and understand the experiences of our customers while using our Services and other products and services
• Make our Services and other products and services better
• Maintain good communication with you, including:
  • Responding to your requests and questions,
  • Giving you updates and new information about your options, us, and our Services, including the Omnipod Insulin Management System,
  • Providing information that you specifically ask for, and
• Protecting you, us, and others, and meeting our legal needs, including:
  • Complying with our legal obligations or cooperating with law enforcement, and
  • Addressing potential illegal activities, fraud, or situations involving threats to someone’s safety

There might also be times when we need to share your Personal Information with others. We will only do this in specific situations as outlined in this Privacy Policy, permitted or required by law, or with your consent.

We may share your Personal Information with trusted people or companies we work with in order to follow this Privacy Policy, as well as to operate and offer our Services and products. This could be with an affiliate, agent, service provider, distributor, or other business partners. When this kind of sharing is necessary, we work to only share the information absolutely necessary for the partner to perform their obligations. We also steps to limit how they can use your Personal Information for anything else.

Also, as we are a growing business, there may be circumstances where we sell or buy businesses or assets to support this growth. In these scenarios (e.g., corporate sale or business mergers), Personal Information might be transferred as part of our business growth. As above any kind of sharing would only be done when necessary and be limited.

Otherwise, we will only share your Personal Information with others when it:

• is permitted or required by law;
• allows us to carry out and apply this Privacy Policy;
• is necessary to carry out, apply, or enforce our Terms of Use;
• helps us protect the rights, property, and personal safety of you and our users, website visitors, or any other person; or
• occurs with your consent.

Additionally, we may use Personal Information, alone or combined with other information we collect, to perform analytics and predictive analyses that help us understand how individuals engage with Services. This allows us to provide, personalize, and improve our Services, communicate more effectively with you, and deliver information, recommendations or reminders that may be relevant to you, such as when an account is created but certain steps or purchases have not yet been completed. These activities may involve automated processing, including profiling, to evaluate or predict interests, preferences, or engagement patterns. They are designed to support improvement to our Products and Services, marketing, and customer communications. You may opt-out of this type of processing at anytime by following the directions in the “How to Exercise Your Rights” section of this policy.

We may also use artificial intelligence or other automated tools to help collect, organize, analyze, or process information in accordance with this Privacy Policy. These tools may assist with activities such as improving our Services, supporting analytics, personalizing communications, detecting issues, or enhancing operational efficiency. Any such use is subject to appropriate safeguards and is designed to support human decision-making and ensure Personal Information is handled consistently with applicable law and this Privacy Policy.

We will take the steps reasonably necessary to keep your Personal Information secure, accurate, and up to date. This includes limiting who on our team – including employees, representatives, partners, and service providers – can access your Personal Information. However, it’s important You know that sharing information online can never be completely secure. So, although we are committed to protecting your Personal Information, we cannot guarantee that it will always be totally secure.

To exercise your right to review, correct, or delete the Personal Information you shared with us through our Services, send your request to our Privacy Officer or use this form to submit your request and find more information about your options. You may also have additional rights depending on where you live. You can learn more in our Consumer Health Data Privacy Policy below.

Some of our Services might be provided through websites that are not ours, or we might offer links to websites that are not ours when we believe it could help you. These outside or third-party websites are offered by and under the control of others. We do not control them in any way, so we are not responsible for their content or actions.

If a website that is not ours asks you to share Personal Information, this Privacy Policy will not apply. You should always review the website’s own privacy policy and terms and conditions before doing anything else. To learn more about our links to third-party websites, check out our Terms of Use.

One more thing: When we provide a link to a website that is not ours, this is not an endorsement in any way.

This Privacy Policy is not the only information you need to keep in mind and should read before using our Services. Our Terms of Use also apply when you access and use our Services.

Insulet Corporation takes your privacy seriously. You may have certain rights regarding our processing of your Personal Information under applicable local state law, including, for example, if you are a consumer in California If our processing of your Personal Information is governed by such laws, the following provisions apply to our processing of your Personal Information, whether collected online or offline, including through (a) visits to our websites, including omnipod.com, insulet.com and investor.insulet.com; (b) phone calls to our customer service centers; and (c) use of any of our products and Services that references our Privacy Policy, including the My Omnipod mobile application or the Discover mobile application and web services.

This Additional State Privacy Information addresses the following topics:

• The Scope of this Additional State Privacy Information
• Our Collection, Use and Disclosure of Personal Information
• Your Privacy Rights
• How to Exercise Your Rights

As defined above and per applicable state privacy laws, “Personal Information” generally means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

As may be required under applicable local law, the chart below describes, for the 12 months preceding the date last updated, above, (a) the categories of Personal Information we have collected about you, (b) the sources of that Personal Information, (c) the business and commercial purposes for use, and (d) the categories of third party recipients of your Personal Information. Unless we inform you otherwise, this section also serves as our “NOTICE AT COLLECTION” by informing you of your Personal Information to be collected in the future and the purposes for its use.

In the last 12 months, we collected the following categories of Personal Information depending on your interaction with us:

Identifiers, including name, address, email address, telephone number, IP address, date of birth.

Internet or other electronic network activity information, including device information from website visits, information regarding a consumer’s interaction with website, application, or advertisement.

Sensory information, including call and voicemail recordings.

Sensitive data, including Personal Information concerning your use of our Services and products, such as blood glucose and insulin dosing data information about your health and health insurance coverage, your age and geolocation data.

In the last 12 months, we collected the categories of Personal Information listed above from the following sources: (1) Directly from consumers; (2) Website users who visit our websites (omnipod.com, insulet.com, investor.insulet.com, advocacyforaccess.com) or other Services, and used those categories of Personal Information for the following purposes:

In the last 12 months, we disclosed the following categories of Personal Information to the following categories of third parties for a business or commercial purpose:

We keep your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Additional State Privacy Information section. The criteria used to determine how long we retain Personal Information include: (i) the length of time we have an ongoing relationship with you and provide the Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of ou r legal position (such as applicable statutes of limitations, litigation or regulatory investigations).

We may disclose certain Personal Information with select third parties for their and our advertising and marketing efforts, including delivering tailored advertising to you on third-party digital properties. Our disclosure of such information may be considered a “sale” or “sharing” of Personal Information as defined under certain state laws, even where no money is exchanged. We do not knowingly “sell” or “share” Personal Information for under-16 individuals. We do not use your sensitive personal data for purposes other than those permitted under applicable local law.

Depending on where you live, you may have the following rights under applicable local law:

1. Right to Copy
   • You may request, up to twice every 12 months, a copy of the specific pieces of Personal Information that we have collected, used or disclosed about you in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance.
2. Right to Know
   • You may request that we provide certain information about how we have handled your Personal Information, including:
     • The categories and specific pieces of Personal Information that we have collected about you;
     • The categories of sources from which we collected your Personal Information;
     • The categories of Personal Information that we sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information;
     • The business or commercial purposes for our collection, disclosure, or sale of your Personal Information; and
     • A list of specific third parties, other than natural persons, to whom we disclosed your Personal Information.
3. Right To Delete
   • You may request deletion of your Personal Information that we have collected about you.
4. Right to Correct
   • You may request correction of your Personal Information that we have collected about you if it is inaccurate or incomplee.
5. Right to Opt Out of “Sale” or “Sharing” of Personal Information/Targeted Advertising
   • You may have a right to opt-out of the “sale” of your Personal Information, the “sharing” of your Personal Information for cross-context behavioral advertising, or our processing of your Personal Information for targeted advertising.
6. Right to Limit Our Use of Your Sensitive Personal Information
   • You may request us to limit how we use your Personal Information to certain permissible purposes.

You have the right to be free from unlawful discrimination for exercising your rights under applicable state law.

• Making Requests
  We will respond to requests in accordance with applicable law if we can verify the identity of the individual submitting the request. You can submit requests to exercise these rights by:
  1. Completing a request using the online form here
  2. Contacting us by telephone (toll-free): 1-800-591-3455
  
  If you would like to exercise your right to opt out of “sales,” “sharing,” or targeted advertising, you can also click here, “Do Not Sell or Share My Personal Information,” and disable Targeting Cookies. We also recognize the Global Privacy Control (GPC) to allow you to exercise these opt out rights. For more information on the GPC, how to enable it, and how to use a browser or browser extension incorporating the GPC signal, see https://globalprivacycontrol.org/. If you visit our websites with a browser transmitting GPC, we will opt you out of “sales”/“sharing”/targeted advertising. If we recognize you on subsequent visits, including when you use other devices or browsers to log in to your account, we will respect your opt-out preference until you change it. If you visit our website using a browser that does not transmit GPC or using a browser or device that you have not associated with an opt-out preference, click the “Do Not Sell or Share My Personal Information” link above to register your opt-out preference.
   
• Requests by authorized agents
  You can have an authorized agent submit a request to us on your behalf by (a) providing us with a written authorization signed by you that designates the agent as your authorized agent for purposes of requesting to exercise rights you may have ; (b) verifying your identity directly with us; and (c) directly confirming with us that the agent is authorized to submit the request.
   
• How we will verify your request
  To prevent anyone other than you, or your authorized agent, from exercising rights you may have with respect to your Personal Information, we follow procedures to verify your, or your agent’s, identity. This process seeks to confirm that the person making a request is the person about whom we have collected personal information or that person’s authorized agent. The verification process involves matching data points that you provide with your request against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. We will use information you provide in your completed request form to verify your identity, and we may request additional information if necessary to complete the verification process.
   
• Appeals
  You may also have a right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please contact us. (See contact information below under “How to get in touch with us”)

To the extent personal information is transferred out of the country where the owner of that personal information lives, such as to our affiliates or business partners in other countries, including in the United States, different standards may apply to how your data is used and protected in those countries. We have appropriate safeguards in place in accordance with applicable legal requirements to ensure that data is adequately protected irrespective of the country. This includes obtaining written assurances from any third party given access to your data so as to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by us and standardized corporate safeguards and contractual measures (based on the European Commission Model Clauses) for internal data transfers to our affiliates in third countries which are deemed to provide an inadequate level of data protection.

Alternative formats of this Privacy Policy are available to individuals with a disability. Please contact us at [email protected] or (866) 941-0155 (toll-free voice telephone line) for assistance.

As our business continues to grow and we introduce new Services and features, we will review and may update this Privacy Policy at any time. We will share any changes we make by posting the new version to our websites. Any changes to this Privacy Policy will apply between us whether or not we have given you specific notice of any changes.

It's important that you stay aware of how we handle your Personal Information – so you should be sure to regularly check our websites for updates. 

We take your experience with us and our Services very seriously, especially if you have questions or concerns, want to exercise your rights, or come across a problem. 

Please let us know if you have any questions about this Privacy Policy, want to exercise your rights, or have a problem or complaint and we will work hard to address it as soon as you share it with us. 

Insulet Corporation 
Attn: Privacy Officer 
100 Nagog Park 
Acton, MA 01720 

Email: [email protected]