California Privacy Rights

Insulet Corporation had adopted this California Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. This policy supplements our other privacy policies.

Insulet Corporation (“Company,” “we,” “our,” or “us”) takes your privacy seriously. We want you to know how we collect, use, share, and protect your Personal Information and about the rights of California Consumers under California law.

This California Privacy Policy addresses the following topics:

  • The Scope of this California Privacy Policy
  • The Company’s Collection, Use and Disclosure of Personal Information
  • Your California Privacy Rights
  • How to Exercise Your Rights
  • Changes to This California Privacy Policy
  • For More Information

Assistance For The Disabled

Alternative formats of this California Privacy Policy are available to individuals with a disability. Please contact us at privacy@insulet.com or (866) 941-0155 (toll-free voice telephone line) for assistance.

The Scope Of This California Privacy Policy

What Is Personal Information?

“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.

Whose Personal Information Is Covered By This Policy?

This “California Privacy Policy” applies to the Personal Information of residents of the State of California in their capacity as consumers (“California Consumers”).

What Personal Information Does This Privacy Policy Cover?

Unless specifically excluded under Cal. Civ. Code. §1798.145, and as stated below, this California Privacy Policy applies to all Personal Information of California Consumers that we collect both online and offline, including through California Consumers’ (a) visits to our websites, including myomnipod.com, insulet.com, investor.insulet.com, and advocacyforaccess.com; (b) phone calls to our customer service centers; and (c) use of our products and services that references our Privacy Policy (collectively, the “Services”).

Whose Personal Information Is Not Covered By This California Privacy Policy?

For purposes of this California Privacy Policy, “Consumer” does not include:

  • Individuals who are NOT California residents.
  • California residents who are Company’s employees, job applicants, or contract workers (collectively, “HR Individuals”), or the emergency contacts of HR Individuals or the dependents or spouses who receive Company benefits by virtue of their relationship to an HR Individual in their capacities as HR Individuals or emergency contacts, dependents, or spouses; or
  • California residents who are employees or other agents of a business engaged in a transaction with Company in their capacities as employees or agents of that business.
  • This California Privacy Policy also does not include the health information of California residents whose health information is collected by a covered entity governed by the Confidentiality of Medical Information Act or the Health Insurance Portability and Accountability Act.

The Company’s Collection, Use And Disclosure Of Personal Information

This section of the California Privacy Policy 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.

Categories Of Personal Information Collected

In the last 12 months,Company collected the following categories of Personal Information about California Consumers:

  • Identifiers, including: name, address, email address, telephone number, IP address.&
  • 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: voicemail recordings.

Sources Of Personal Information and Purposes For Using Personal Information

In the last 12 months, Company collected the categories of Personal Information listed above from the following sources: (1) Directly from Consumers; (2) Website Users who visit our websites (myomnipod.com, insulet.com, investor.insulet.com, advocacyforacces.com), and used those categories of Personal Information for the following purposes:

Categories of Personal Information Collected in the Last 12 Months

Sources of that Personal Information

Business Purposes and Commercial Purposes for Collecting that Personal Information

 

Identifiers

 

  • Name, address, email, phone number, IP address

From:

 

(1) Website Users:

 

myomnipod.com

insulet.com

investor.insulet.com

advocacyforaccess.com

 

Social Media, such as Facebook (only through direct messaging by Consumer to us)

 

(2) Directly from Consumers (by phone or mail)

 

 

  • Performing services, including providing customer service, processing or fulfilling orders and transactions.
  • Verifying new or prospective customer information.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety Company products and services, and to improve, upgrade, or enhance the service and products.
  • Communications about special events, promotions and surveys.
  • Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with new or prospective customers, including regarding questions and feedback.
  • Auditing related to a current interaction with customers and concurrent transactions, including, but not limited to, counting impressions to unique visitors, verifying positioning and quality of impressions, and auditing compliance with the law.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

 

Internet or other electronic network activity information

 

  • Device information from website visits, information regarding a Consumer’s interaction with website or application.

 

From:

 

Automated technologies in the website, including Google Analytics

  • Understanding website usage by users
  • For marketing and advertising

Sensory information

 

  • Voicemail records

From:

 

Directly from Consumers (by phone)

  • Performing services, including providing customer service, processing or fulfilling orders and transactions,
  • Verifying new or prospective customer information.
  • Communications about special events, promotions and surveys.
  • Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with new or prospective customers, including regarding questions and feedback.

 

 

Disclosure Of Personal Information To Third Parties

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

 

Category of Personal Information

Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last 12 Months

 

Identifiers

 

  • Government agencies, law enforcement, and other parties as required by law, including in litigation

 

No Sale Of Personal Information

The Company does not and will not sell California Consumers’ Personal Information.

YOUR CALIFORNIA PRIVACY RIGHTS

  1. Right to Know

California Consumers have the right to submit a verifiable request to know:

  • The categories and specific pieces of Personal Information that Company has collected about them;
  • The categories of sources from which Company collected the Personal Information
  • The categories of Personal Information that Company sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information; and
  • The business or commercial purposes for Company’s collection, disclosure, or sale of the Personal Information.
  1. Right To Delete
  • California Consumers have the right to submit a verifiable request for deletion of their Personal Information that Company has collected from the Consumer.
  1. Right to Opt Out of Sale of Personal Information

  • California Consumers have a right to opt-out of the sale of the Personal Information.  However, as stated above, Company does not and will not sell Personal Information.

HOW TO EXERCISE YOUR RIGHTS

  1. Making Requests

Company will respond to requests for access to or deletion of Personal Information in accordance with applicable law (“CCPA Request”)if it can verify the identity of the individual submitting the request. California Consumers can exercise their rights in the following ways:

  1. Email a request including full name, email address, phone number and state of residence, stating whether it a request for access to, or a request for deletion of, Personal Information, to privacy@insulet.com
  1. Contact by telephone (toll-free): (866) 941-0155

  1. Requests By Authorized Agents

You can have an authorized agent submit a CCPA 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 a CCPA request; (b) verifying your identity directly with us; and (c) directly confirming with us that the agent is authorized to submit the request.

  1. How We Will Verify Your Requests

To prevent anyone other than you, or your authorized agent, from exercising the right to know or the right to delete 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.

Changes to This California Privacy Policy

Our commitment to be the leading provider of innovative insulin delivery systems means that our business will continue to evolve as we introduce new services and features. Because of this, from time to time, our policies will be reviewed and may be revised. We reserve the right to change this California Privacy Policy at any time and notify you by posting an updated version of the Privacy Policy on the Website. It is your responsibility to periodically check the Website so that you are aware of what information we collect, how we process and use it, and under what circumstances we might disclose it. The amended California Privacy Policy will apply between us whether or not we have given you specific notice of any change.

For More Information

If you have any further questions relating to our California Privacy Policy, or if you have a problem or complaint, please contact us by writing to:

Insulet Corporation
Attn: Privacy Officer
100 Nagog Park
Acton, MA 01720
Email: privacy@insulet.com
Toll-Free Phone: (866) 941-0155

 

Last Updated: June 22, 2020