Insulet Corporation Privacy Policy

NOTE: TO ACCESS THE PRIVACY POLICY RELEVANT TO HEALTHCARE PROFESSIONALS AND BUSINESS CONTACTS PLEASE CLICK HERE

Privacy Notice Insulet Middle East

This Privacy Notice describes how the Insulet entity that services your country ('we', 'us') (to access the details of your local Insulet entity please click HERE) collects personal information about you; how we use this information, and your rights in relation to this information.

We respect the importance of your privacy. We will only use your personal information in the ways we explain in this Privacy Notice. Please read this Notice carefully to understand more. You can contact our Data Privacy Office at any time at [email protected]

1. Personal Information we Use

We will collect personal information about you from a variety of sources, including information we collect from you directly (e.g. when you contact us and provide information to us), information we collect on www.omnipod.com or other our other websites (the "Websites"), and information we collect about you from other sources, such as other web-based communication channels or services we create, use, offer or operate.

1.1. Information we Collect Directly from You

The categories of information that we may collect directly from you include the following:

personal details (e.g. name, date of birth);
contact details (e.g. phone number, email address, postal address or mobile number);
technical device information (e.g. the Internet Protocol address for your device or device identifier);
medical information – any information about your diabetes condition and treatment (e.g. information about your use of Insulet products or services, health data, health insurance coverage).
Your Healthcare Provider information (e.g. name);
Your Healthcare Insurance Provider information.

1.2. Information we Collect from Other Sources

The following are examples of the categories of information we may collect from other sources

personal details (e.g. name, date of birth);
contact details (e.g. phone number, email address, postal address or mobile number);
health data from data management platforms you use.

2. How we use Personal Information and the Basis on which we Use it

We may use your personal information for the following purposes

Identification and authentication: We use your identification information to verify your identity when you access and use our services and to ensure the security of your personal information.
Operating the services: We process your personal information to provide the services and products you have requested. We do this to meet any contractual obligations we have to you and/or third parties (for example to deliver services to you), or in order to provide the best service possible if we do not have a contract with you.
Responding to your requests and inquiries: We use your personal information to respond to any requests and inquiries you make to us.
Improving our services: We analyse information about how you use our services, or feedback that you provide, to provide an improved experience. We perform business analytics and aggregated reports for use internally and/or share with our business partners to better understand our markets and improve our customer’s experience with our products and services.
Exercising our rights: We may use any of the categories of your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or the contract.

When you provide your consent to us to use your personal information you always have the right to withdraw your consent. Please contact us using the details above if you wish to withdraw your consent.

3. How we Use Your Medical Information and the Basis on which we Use it

We may use your medical information when you wish to use or are using our products and/or services for the following purposes:

Product Support: We may use your Medical Information for product support, and to evaluate the quality of service that you receive. Where needed, we rely on your consent when we are using your Medical Information for this purpose.
Training on the use of the DASH System: we process your personal data to invite you to and provide you with trainings on the use of the DASH System, or other Insulet products or services. We process your contact details, information on which product you use, information you provide during the training and information we may receive from your health care provider. After the training, we may send you a survey by email to request your feedback on the training, in order to evaluate and improve the training. We process your personal data based on the necessity of processing for reasons of public interest in the area of public health, namely to ensure a high standard of quality and safety of our products and services. Further, we evaluate your survey feedback to improve our trainings based on your consent.
Emergencies: If you require emergency treatment in order to prevent a serious threat to life, health, or safety, and we are unable to obtain your consent, we may disclose your Medical Information to a family member or relative who is involved in your care.
Legal Claims: We may use or disclose your Medical Information to the extent necessary to establish, exercise or defend legal claims when it is in our legitimate interests. You will be notified of any such uses or disclosures to the extent permitted by law.
Public Health: We may disclose your Medical Information for public health activities and purposes in the public interest (including to protect against serious cross-border threats to health) where permitted by law. The disclosure will be made for the purpose of preventing or controlling disease, injury or disability. We may also disclose your Medical Information, if directed by the public health authority and permitted by law, to a foreign government agency that is collaborating with the public health authorities.
Health Regulators: We may disclose Medical Information to health regulators for activities authorised by law, such as audits, investigations, and inspections where necessary in the public interest for the quality and safety of medical devices or where required under a legal obligation. Health regulators seeking this information include government agencies that oversee the healthcare system and other government regulatory programmes.
Criminal Activity: We may disclose your Medical Information where we consider the disclosure is necessary for reasons of substantial public interest as permitted by law such as to prevent or lessen a serious and imminent threat to the health or safety of a person or the public (including to a law enforcement authority where required by law).
Improving our services: We may process your Medical Information when we analyze information about how you use our services, to provide an improved experience for our customers, and to improve and evaluate our services. This may include aggregating your information to perform data analytics. Where necessary, we will obtain your consent first.

When we rely on your consent to use your Medical Information you always have the right to withdraw your consent. Please contact us using the details above if you wish to withdraw your consent. You can also contact us to find out more about the precise circumstances in which we use your Medical Information for the purposes described above.

4. Your Rights Over Your Personal Information

You have certain rights regarding your personal information (including your Medical Information), subject to local law. These include the following rights to:

access your personal information;
rectify the information we hold about you;
erase your personal information;
restrict our use of your personal information;
where required by local law, receive your personal information in a usable electronic format and transmit it to a third party (the right to 'data portability').

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. Please note that we will likely require additional information from you in order to honour your requests.

If you would like to discuss or exercise such rights, or if you have any complaints about our use of your personal information, please contact us using the following webform.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to a data protection authority, e.g. to the data protection authority which is supervising the Insulet entity that services your country.

5. Information Sharing

We may share your personal information (including health information) with third parties under the following circumstances and to the extent permitted by law

Service providers and business partners. We may share your personal information, including your Medical Information, with our service providers and business partners that perform customer support services and other business operations for us. For example, we may partner with other companies to fulfil orders, optimize our services, provide online product trainings, support email and messaging services and analyse information. We may transfer your personal information to partners and third parties outside of your country, to countries which may not protect your personal information in line with your country of residence. We will request your consent for such transfers where needed.
Insulet Group companies. We are owned by Insulet Corporation, so we work closely with other businesses and companies that fall under the Insulet family. We may share certain information about our business relationship with you including the products and services provided to you and your use of the same, your browsing history on our website, etc., with Insulet Corporation, and other Insulet companies for business operations and marketing purposes.
Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Notice.

6. Information Security and Retention

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will keep your personal information for as long as we have a relationship with you. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations and regulators' expectations, as well as the amount of time necessary for us to maintain records for analysis and audit purposes. We may also retain records to investigate or defend potential legal claims and to deal with any complaints raised. We will not retain your personal information longer than is permitted by applicable law.

7. International Data Transfer

The third parties with which we share personal data, including your health data, may be located in other countries than the country you reside in, including the European Economic Area and the United States of America, for example our group companies, service providers and business partners. These third parties may be located in countries that have a lower legal protection level for personal data than applicable in your country. We will only provide your personal data to third parties that handle your personal data confidentially and provide appropriate protection in line with data protection law that apply to Insulet, 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 other relevant local governments or authorities, as applicable). For more information on the appropriate safeguards in place, please contact us using the following privacy webform.

8. Changes to the Notice

You may request a copy of this privacy notice from us using the contact details set out above.

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 Privacy Notice at any time and notify you by posting an updated version of the Privacy Notice on the Websites. It is your responsibility to periodically check the Websites so that you are aware of what information we collect, how we process and use it, and under what circumstances we might disclose it. Where we are required to do so, we will collect new explicit consents from you.

We may modify or update this privacy notice from time to time. You will be able to see when we last updated the privacy notice because we will include a revision date. Changes and additions to this privacy notice are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal information.