Insulet Corporation Privacy Policy

Last Revised September 15, 2022

Preamble

Insulet Canada Corporation ("Insulet" also referred to as "us" or "we") respects the privacy of every individual who visits our websites, mobile applications, or other web- or cloud-based or -enabled channels or services owned or operated by Insulet and/or our affiliates (collectively, the “Services”). We are committed to the fair and confidential processing of their Personal Information in accordance with this Privacy Policy (as defined below) and applicable Canadian privacy laws.

This privacy policy, as revised from time to time ("Privacy Policy"), is incorporated into and forms part of the Terms of Use, which outlines the terms and conditions you agree to when accessing and using the Services. Please review this Privacy Policy carefully.

This Privacy Policy applies to residents of Canada. If you are a resident of another country, please click here to navigate to the relevant page for applicable privacy policy information applicable in your country of residence.

By submitting your Personal Information (as defined below) to us or accessing and using the Services, you agree to the collection, use, and disclosure of your Personal Information in accordance with this Privacy Policy. If you refuse, are unwilling, or cannot accept the Terms of Use, or do not consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy, then do not use the Services.

Policy Change

Insulet reserves the right, at its sole discretion, to modify this Privacy Policy at any time. Changes to this Privacy Policy will be posted on this page. This Privacy Policy was last updated on the date noted at the top of this Privacy Policy. Your continued access or use of the Services constitutes your acceptance of the Privacy Policy in effect at the time of that access or use. Although we will endeavour to bring significant changes to the Privacy Policy to the general attention of users of the Services, it is your responsibility to review the Privacy Policy frequently.

Personal Information

In this Privacy Policy, "Personal Information" means information about an identifiable individual. Personal Information may include, but is not limited to, your name, mailing address, e-mail address, Internet Protocol address, unique personal identifiers, geolocation data, account name, social insurance number, medical information, health insurance information, commercial information, and telephone number. Personal Information does not include business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, title or business address or telephone number of an employee of an organization.

Personal Information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

How we Collect your Personal Information

Typically, we collect your Personal Information in one or more of the following circumstances (or in such other purposes with your consent):

Internet Protocol (IP) Addresses

When you access the Internet using your computer, your Internet service provider assigns you an IP Address. Generally, every time you connect to the Internet from a different device, your IP Address changes. In some circumstances (i.e., with some broadband connections) your IP Address may not change in which case, it can be associated with your particular computer. In order to identify your device or certain preferences for your use of the Services we may collect your IP Address and other information. Examples of the type of information that can be collected using your IP Address include your type of internet browser, the type of operating system you are using and your general geographic area. Insulet, or its authorized agents, may also use your IP Address to collect and report aggregate information on how the Services are being used and ways in which the Services can be improved.

Web Log Information

We may also collect web log information which is non-Personal Information that is collected by the server that hosts the Services, including, but not limited to, the date and time you visited the Services, the type of Internet Browser you are using, technical and device information about your use of our Services and the type of computer operating system you are using. Weblog information may be collected and used by Insulet or its authorized agents in aggregate to assess how the Services are being used and how to improve the Services.

Our Services use or enlist third-party services which use a technology known as "Cookies". A Cookie is a token that a server gives to your browser when you access a website on the Internet. Cookies are capable of storing many types of data. Your use of the Services constitutes your consent to our use of Cookies. Cookies (which term also includes, for purposes of this Privacy Policy, other technologies such as web beacons and pixels that serve similar functions) help provide additional functionality to the Services, save your preferences for use of the Services or help us analyze the Services usage more accurately. For instance, our server may set a Cookie that keeps you from having to enter a password more than once during a visit to the Services. In all cases in which Cookies are used, we will not collect Personal Information without your consent. The use of Cookies is a common practice adopted by most major sites to better serve their users. You may review Insulet’s Cookie Policy, which contains information on how the Services use Cookies.

You should be aware that operators of third-party websites and services linking to or linked from the Services may also collect your Personal Information through the use of Cookies. Insulet, its affiliates and any directors, officers, employees, agents, contractors, subcontractors or agents of the foregoing shall not be responsible for how such third-party operators collect, use or disclose your Personal Information. You need to contact these operators directly for information on their data collection, use and disclosure policies. Your navigation to a third-party website or service is entirely at your own risk and subject to the terms and conditions of such websites or services.

Contacting Insulet By E-mail, Phone, Etc.

If you interact with us, whether in person, by phone, email, social media or otherwise, including if you are interested in acquiring our products or services, sign-up to receive newsletters or other communications, or respond to surveys and questionnaires, we may collect information (including Personal Information) that you provide to us during these interactions.

Other Collection of Personal Information

Insulet may also collect your Personal Information with your consent or as permitted or required by law. How we obtain your consent (i.e., the form we use) will depend on the circumstances, as well as the sensitivity of the information collected. For example, when accessing the Services as a non-registered or registered user, you may be asked to voluntarily provide certain Personal Information. You will be informed of what information is required and what information is optional in order to access the Services. If you choose to provide Personal Information to us, we assume that you consent to the collection, use and disclosure of your Personal Information as outlined in this Privacy Policy.

You understand that the Services may include certain functionalities, which may require you to provide certain Personal Information in order to benefit from said functionalities. These may include, without limitation, the creation of an account, the completion of a contact information form, the purchase of products or services or testing certain products or services of Insulet. The Services shall prompt you to input the required information. Should you choose not to provide the information requested, you may not be able to access or use some functionalities of the Services.

If you provide Personal Information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy.

How we Use and Disclose your Personal Information

Insulet may use your Personal Information (i) to respond to your questions or requests for additional information; (ii) to provide you with the Services or information that you have specifically requested, or that Insulet may ask you if you would like to receive (Example: e-mail refill reminders, e-newsletters); (iii) to personalize any interactive tools to better facilitate your use of the Services; (iv) to develop future e-newsletter topics for the Services; (v) to conduct research and analysis to improve the Services; (vi) to understand how we can improve our products and services; (vii) to contact you relating to our Services; (viii) to collect opinions and comments in regard to our Services; (ix) to provide you with information that we think may interest you, including in regards to our products and services; and (x) to investigate legal claims. You may opt-out of some of these purposes by contacting us. Any marketing communication shall require you to opt-in prior to you receiving them.

Insulet does not sell your Personal Information to third parties. Insulet does not disclose your Personal Information unless the disclosure is permitted or required by applicable law or required in order for Insulet to perform the Services.

In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of our company, in whole or in part, your Personal Information may be transferred as part of the transaction.

Insulet may also use aggregate information that does not contain Personal Information (a) to track and monitor visitors' use of the Services; (b) to track and monitor visitors’ understanding of diseases and medications; and (c) to track and monitor visitors’ use of medications. Insulet may also disclose aggregated information that does not include Personal Information to third parties.

By providing or transmitting any comments, ideas, concepts, know-how, techniques, or other similar information (a “Communication”) to Insulet, whether in person, by phone, email, social media or otherwise, you grant to Insulet and all of its affiliates, an unrestricted, irrevocable licence to use, reproduce, display, modify, transmit, distribute, publish, broadcast or post your Communication for any purpose and without compensation to you or your prior approval. However, we will not release your name in connection with such Communication unless: (a) you grant us permission to do so; (b) we first notify you that the Communication you submit to a particular part of the Services will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Consent to Other Purposes

Where we want to use your Personal Information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose (unless we are otherwise permitted or required by law).

Withdrawal of Consent

You may withdraw your consent to our collection, use or disclosure of your Personal Information at any time by contacting our Privacy Officer, whose contact information is provided below. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain Services to you.

Before we implement the withdrawal of consent, we may require proof of your identity.

Transfer of Personal Information to Service Providers

Insulet may have service providers perform services relating to the development, operation and maintenance of the Services or relating to other services including but not limited to e-commerce providers, payment card processors, telephone and technical support providers, order fulfillment, hosting, data storage and processing service providers, and research and analytics providers. ("Service Providers"). These Service Providers may have access to your Personal Information, as is reasonably necessary, for the purpose of providing their services to Insulet.

If we provide your information to Service Providers, then we require that the Service Providers maintain the confidentiality of your Personal Information and keep your Personal Information secure. We also require that they only use your Personal Information for the limited purposes for which it is provided. In some circumstances, we may permit our Service Providers to retain aggregated, anonymized, or statistical information that does not identify you. We do not authorize the Service Providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their direct marketing purposes. If you would like more information about our Service Providers, please contact us using the contact information set out below.

Retention of Personal Information

We retain your personal information in our offices and servers located in Oakville, Canada, as well as in the United States. We may also retain your personal information in the servers of our Service Providers which are located in the United States.

As we are a U.S.-based entity, your Personal Information may be transferred outside your country of residence, including to the U.S. As a result, your Personal Information may be subject to the laws of those foreign jurisdictions, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of that other country, pursuant to that country’s laws.

We will use, disclose or retain your Personal Information only as permitted or required by law.

Information Security

We have implemented physical, organizational, contractual and technological security measures with a view to protecting your Personal Information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measures outlined above, you must be aware that transmissions over the Internet cannot be guaranteed to be completely secure and such transmission or information storage is not 100% secure or error-free. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information set out below.

To the maximum extent permissible under applicable law, Insulet, its affiliates and any directors, officers, employees, agents, contractors, subcontractors or agents of the foregoing do not represent, warrant or guarantee that Personal Information will be protected against misuse, loss or modification, nor do such parties accept liability for the security of a user's Personal Information submitted on or via or in connection with the Services.

Access to and Correction of Personal Information

We will take steps to ensure that your Personal Information is kept as accurate, complete and up-to-date as reasonably necessary. However, we will not routinely update your Personal Information, unless such a process is necessary.

If we hold Personal Information about you, you may make a written request to access, change and update your Personal Information at any time. You may also challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your Personal Information. Any such identifying information will be used only for this purpose. Requests regarding your Personal Information can be made to our Privacy Officer, whose contact information appears in the “Contact Us” section of this Policy.

Third-Party Websites and Services

This Privacy Policy applies only to our Services. This Privacy Policy does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third-party websites or products or services.

Contact Us

If you would like to request a copy of your Personal Information in our possession, if you would like to request that we correct such information, or request that we delete any such information, please submit a request. Additional information about requests that you may make is available at the link.

You may request assistance with privacy requests by telephone at: 1-855-POD-INFO (1-855-763-4636).

All other requests, questions or concerns regarding our use of your Personal Information should be directed, in writing, to:

Privacy Officer

E-mail: [email protected]

The Privacy Officer phone number is 1-866-941-0155.

Our mailing address is:
Insulet Canada Corporation
1540 Cornwall Rd
Suite 201
Oakville, Ontario
L6J 7W5

To report an adverse event, medical device incident or product complaint about the Omnipod® Insulin Management System please call 1-855-POD-INFO (1-855-763-4636). The contents of this site are for information purposes only and are not, in any way, intended to replace or substitute the advice of your physician. This site does not provide medical advice. When using the Services, please read and accept any applicable terms and conditions. The Omnipod® Insulin Management System and the Omnipod DASH® Insulin Management System can be obtained through a statement of medical necessity, as required under applicable law. Before deciding on the Omnipod® Insulin Management System or the Omnipod DASH® Insulin Management System, you must discuss with your healthcare practitioner any applicable benefits or potential risks, as well as the responsibilities that come with insulin pump therapy.