Consumer Health Data Privacy Policy
Last Updated: March 29, 2024
This Consumer Health Data Privacy Policy provides information regarding how Insulet Corporation (“Company,” “we,” “our,” or “us”) processes “consumer health data” as defined by Washington’s My Health My Data Act (“WMHMDA”) and other applicable consumer health privacy laws. In the event of a conflict between the Insulet Privacy Policy and this Consumer Health Data Privacy Policy, this Consumer Health Data Privacy Policy will control with respect to the processing of consumer health data.
Consumer health data we collect
We collect consumer health data in connection with certain of our products and services, such as when you visit our Websites or make use of our Applications or other online offerings (collectively, the “Services”). The type of consumer health data depends on the specific product or service that you use or receive and your interactions with us. Examples of consumer health data that we collect may include:
- information about your health-related conditions, symptoms, status, diagnoses, testing, treatments, or medications, including your use and purchase of such medication;
- information about medical interventions;
- measurements of bodily functions, vital signs, symptoms, or health characteristics;
- information that could identify you seeking health care services, such as completing forms on our website seeking information on how to access our products; and
- other information that may be used to infer or derive data related to the above or other health information.
How we use consumer health data
We primarily collect and use consumer health data as necessary to provide you with products or services that you request or for other purposes for which we obtain your consent as required by applicable law. This may include the following:
- provide our products and services to you, including the Services described above;
- effectively communicate with you;
- respond to your requests and inquiries;
- provide you with information on our products and services;
- provide you with updates and options about our products and services;
- analyze our customers' experiences with our products and services, including the Services described above;
- improve our products and services;
- comply with legal obligations and respond to legal process;
- marketing purposes, such as to provide you with information which we believe interests you; and
- any other lawful purpose for which we obtain your consent.
We may also collect and use consumer health data as necessary to protect the rights, property or personal safety of Insulet, another Insulet user, website visitor, other users of the Services, or any member of the public, such as to:
- prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal under applicable state law or federal law;
- preserve the integrity or security of systems; and
- investigate, report, or prosecute those responsible for any such action that is illegal under applicable state law or federal law.
We may deidentify consumer health data so that it cannot reasonably be reidentified by us or by another person, and we may use this deidentified data for any reason permitted by applicable law. If we deidentify information that was originally based on consumer health data, we maintain and use that information in deidentified form and will not attempt to reidentify the data, except as otherwise permitted under applicable law.
How we share consumer health data
We may share each of the categories of consumer health data described in this Consumer Health Data Privacy Policy as necessary to provide you with a product or service you request, with your consent, or for certain security-related purposes, as described above. We may also share consumer health data:
- as required by law;
- as necessary to implement and/or enforce our terms of use agreement;
- with an agent, service provider, distributor, or other company in a business relationship with Insulet to operate the Services, fulfill the purposes set out above, or otherwise deliver a product or service. When we use another company to perform a function of this nature, we endeavor to provide them only with the information that they need to perform their specific function and we instruct them to limit their use of the consumer health data accordingly;
- with other Insulet affiliates for business operations; and
- in the event of a corporate sale, merger, reorganization, dissolution, or similar event.
We do not share your consumer health data via web trackers or cookies unless you have opted in to allow us to set optional cookies. If you have opted in and wish to opt out, you may do so as described in our Cookie Policy.
Sources of consumer health data
We collect consumer health data directly from you and automatically as you interact with our Services. The specific sources of consumer health data depend on the product or service that you use and your interaction with us.
Third parties with which we share consumer health data
As necessary for the purposes described above, we share consumer health data with the following categories of third parties:
- agents, service providers, distributors, or other companies in a business relationship with Insulet;
- parties to a business transfer;
- third parties, such as government agencies and law enforcement in response to legal process or other third parties as necessary to protect Insulet, another Insulet user, website visitor, other users of the Services, or any member of the public; and
- other third parties as necessary to provide the services or products you requested or with your consent.
How to exercise your rights
Under the WMHMDA, subject to certain exceptions, you may have the right to access or delete consumer health data about you, or receive a list of third parties with whom your consumer health data was shared. You also may have the right, subject to certain exceptions, to withdraw consent relating to the use and sharing of your consumer health data. To exercise these rights, you may use the online form here or contact us by telephone (toll-free) at 1-800-591-3455. We will use information you provide in your request to verify your identity, and we may request additional information if necessary to complete the verification process.
If your request to exercise a right under the WMHMDA is denied, you may appeal that decision by contacting us as described below. If your appeal is unsuccessful, you can lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
If you have questions about this Consumer Health Data Privacy Policy or would like to make a complaint, you can contact us at:
Insulet Corporation
Attn: Privacy Officer
100 Nagog Park
Acton, MA 01720
Email: [email protected]
Toll-Free Phone: (866) 941-0155
Supplement to Consumer Health Data Privacy Policy for Nevada consumers
This supplement applies to Nevada consumers and provides additional disclosures required by Nevada’s consumer health privacy law.
Requesting Changes to Consumer Health Data. You may request a change to your consumer health data by using the online form here or contacting us by telephone (toll-free) at 1-800-591-3455. If your request to change your consumer health data is denied, you may appeal that decision by contacting us as described above.
Third Party Collection of Consumer Health Data. Third parties may collect consumer health data over time and across different websites or online services when you use our Services. Further details regarding Insulet’s use of strictly necessary and performance cookies are disclosed in Insulet’s Cookie Policy. If you have previously opted in to third-party cookies on our Websites, you may choose to opt out of certain third-party cookies by changing your preferences as described in our cookie policy or more generally by using a service such as:
- The Network Advertising Initiative. See: https://optout.networkadvertising.org/
- Global Privacy Control. See: https://globalprivacycontrol.org/
Changes to this Consumer Health Data Privacy Policy. Insulet is an innovative medical device company improving the lives of people with diabetes and other conditions through its Omnipod delivery system. This 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 Consumer Health Data Privacy Policy at any time and notify you by posting an updated version of the 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 Consumer Health Data Privacy Policy will apply between us whether or not we have given you specific notice of any change.