This Privacy Statement was last updated on March 23, 2022.
The mission of Embecta Corp. and its affiliates and subsidiaries (“embecta” or “we”) is to develop and provide solutions that make life better for people living with diabetes. In doing so, we collect, use, share and otherwise process individually identifiable data about visitors to our Sites (defined below), customers, business contacts, healthcare professionals, patients, individual end-users, business partners and other external parties with whom we interact (“Personal Data”). embecta takes data privacy seriously and we believe that carrying out our business activities in compliance with applicable privacy and data protection laws is fundamental to our business success.
This external Privacy and Cookies statement (“Privacy Statement”) describes our practices in connection with information that we or our service providers collect through our (or their) websites, applications and other sources (such as embecta partner websites and/or applications) as part of embecta’s services (collectively, the “Sites”). Additional terms may apply when you access specific services in some areas of this website, through mobile applications, or when you click on links that navigate away from this website. Your use of the Sites that link to this Privacy Statement are subject to this Privacy Statement and the Terms of Use of the Site.
1. Collection | We collect names, contact details, and other Personal Data related to our commercial relationships. |
2. Use | We use Personal Data to provide our products and services and respond to inquiries, to manage accounts and maintain business operations, to provide relevant marketing, and to fulfill other business and compliance purposes. |
3. Sharing | We share Personal Data as necessary to provide our products and services and respond to requests, and to fulfill other business and compliance purposes. |
4. Marketing choices | You have control over how we use Personal Data for direct marketing. |
5. Cookies | We use cookies on our Site and in our communications, and provide choices on use of cookies, including third party targeting and advertising. |
6. Data subject rights | Certain laws, like the EU’s General Data Protection Regulation (“GDPR”), provide for certain rights to request access, rectification, deletion or other actions regarding individuals’ Personal Data. |
7. Data security | We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration or unintentional destruction. |
8. Cross-border data transfers | We provide appropriate protections for cross-border transfers of personal data where specified by law. |
9. Notice to California consumers | California, USA consumers may have additional rights with respect to their Personal Data under the California Consumer Privacy Act of 2018 ("CCPA"). |
10. Other issues | We provide other information in this Privacy Statement about: (i) the legal basis for collecting and processing Personal Data, (ii) the consequences for not providing Personal Data, (iii) automated decision-making, (iv) do-not-track (DNT) signals, (v) data retention, (vi) employee and contractor issues, and (vii) changes to this Privacy Statement. |
11. Contact us | Please contact us as detailed below with any questions. |
We may collect, use, share and otherwise process the following categories of Personal Data about you that have been obtained either directly from you, from third parties (e.g., your employer or the healthcare institution you work for), or automatically collected through your use of the Sites:
Diabetes Care Application (“DC App”)
We use the above categories of Personal Data for the following purposes:
Purpose of Use | Categories of Personal Data |
Delivering products and services, including
| Identification data; product data; communication details; health-related information
Registration and account details; health-related information; automated data for the DC App only |
Providing customer service and engaging in
| Identification data; product data; communication details; health-related information
Registration and account details; health-related information; automated data for the DC App only
|
Marketing and customer relationship
| Identification data; professional data; product data; communication details; health-related information |
Product/service development and improvement of quality and functionality of products and service
| Product data
Registration and account details; automated data for the DC App only
|
Training records of clinical and other staff
| Identification data; professional data; training data; health-related information
|
Security and fraud prevention activities
| Identification data; professional data; communication details; product data; financial or payment data
Registration and account details; automated data for the DC App only
|
Complying with legal obligations or
| Identification data; professional data; product data; communication details; financial or payment data
Registration and account details; health-related information; automated data for the DC App only |
We share with or disclose Personal Data to the following categories of recipients:
You have control regarding our use of your Personal Data for directing marketing. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication for which you have previously provided your consent, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication or contact us as detailed below.
We use and allow certain trusted partners to use cookies, web beacons and similar tracking technologies (collectively, "cookies") on our Site.
What are cookies?
When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. Cookies are small amounts of data that are stored on your browser, device, communication or the page you are viewing. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website. More information about cookies and how they work is available at Cookiepedia.
How do we use cookies?
We use cookies to provide the Site, products, and services, gather information about your usage patterns when you navigate this Site in order to enhance your personalized experience, and to understand usage patterns to improve our Site, products, and services. We also allow certain trusted partners to place cookies on our Site in order to collect information about your online activities on our Site over time and across different websites you visit. This information is used to provide advertising tailored to your interests on websites you visit, also known as interest-based advertising, and to analyze the effectiveness of such advertising.
Cookies on our Site are generally divided into the following categories:
What are your options if you do not want cookies on your computer?
You are free to decide which of the above-described categories of cookies you would like to permit on your browser by clicking the Cookies Options link in the website footer. Please note that depending on the settings you choose, the full functionality of our website may no longer be available. Additionally, you can review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise browser-based choices you may have for certain cookies.
If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of the Sites, and you may be required to re-enter your log-in details. For more information on the practical implications of changing cookie settings, you can consult this external page: https://www.allaboutcookies.org.
Where required by applicable law (such as GDPR), you may have the right to obtain confirmation that we maintain certain Personal Data relating to you and the corresponding processing activities, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete or anonymize , or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us as outlined below. You may also have the right to request information about third parties with whom we have shared your Personal Data, as well as the right to request review of decisions based solely on automated data processing. In particular, you have the right to object to our use of Personal Data for direct marketing and in certain other situations at any time. Contact us below for more details. Please note that we need to retain certain Personal Data as required or permitted by applicable law.
You may also have the right to lodge a complaint with the relevant data protection supervisory authority.
embecta takes reasonable steps to protect any Personal Data you provide to us and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Unless otherwise stated on the relevant page of the Site or through an embecta partner mobile application, embecta uses general security standards but has not taken additional action to secure data provided to its sites or from its applications or from an embecta partner mobile application, and such transmissions are subject to normal Internet security risks. As noted, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from this Site may not be secure, and you should therefore take special care in deciding what information you send to us or to embecta partners. Please keep this in mind when disclosing any Personal Data to embecta or to any other party via the Internet. Moreover, when you use passwords, ID numbers, or other special access features on this Site, it is your responsibility to safeguard them.
Where permitted by applicable law, we transfer Personal Data to various jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers. With respect to transfers originating from the European Economic Area ("EEA"), we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required by applicable law. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.
CA Personal Information. If you reside in California, we are required to provide additional information to you about how we use and disclose your Personal Data, and you may have additional rights with regard to how we use your Personal Data. We have included this California-specific information below.
Consistent with the “What Personal Data Do We Collect” section above, we collect certain categories and specific pieces of information about individuals that are considered personal information in California (“CA Personal Information”). This includes:
Sources. As detailed above, we collect certain categories of CA Personal Information either directly from you and other third parties, including:
Purposes. We collect CA Personal Information for the business and commercial purposes described in the “How Do We Use Personal Data?” section above. We also share and/or disclose your CA Personal Information for business purposes consistent with the “How Do We Share Personal Data” section above.
Sale of CA Personal Information. In the past 12 months, we have not knowingly sold any CA Personal Information, including no actual knowledge that we have sold the CA Personal Information of California residents under the age of 16.
California Consumer Rights. Subject to certain exceptions, as a California resident, you have the right to: (i) request access to your CA Personal Information; (ii) request deletion of your CA Personal Information; and (iii) request information about the CA Personal Information about you that we have disclosed and/or "sold" (as such term is defined under California law) to third parties within the past 12 months. Should you wish to request the exercise of your rights with regard to your CA Personal Information, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. Please contact us as detailed below. You also have the option of designating an authorized agent to exercise your rights on your behalf. For authorized agents submitting requests on behalf of California residents, please contact us as described below, with any evidence you have that you have been authorized by a California consumer to submit a request on their behalf.
(i) What is the legal basis of processing?
Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including, without limitation: (a) as necessary to perform a transaction (such as in order to provide the products and services you requested); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to substantiate tax liability); (c) consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies); and (d) necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Site).
(ii) What are the consequences of not providing Personal Data?
You are not required to provide all Personal Data identified in this Privacy Statement to use our Site or to interact with us offline, but certain functionality will not be available if you do not provide certain Personal Data. If you do not provide certain Personal Data, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.
(iii) Do we engage in automated decision-making without human intervention?
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
(iv) Does the Site honor do not track ("DNT") signals sent via browsers?
Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we do not respond to DNT signals at this time.
(v) How long do we retain Personal Data?
We typically retain Personal Data related to marketing activities for as long as you accept marketing communications from us, and upon request we will securely delete such data in accordance with applicable law. For Personal Data that we collect and process for other purposes described above, we typically retain such Personal Data for no longer than for the period necessary to fulfill the purposes outlined in this Privacy Statement and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.
(vi) How will we handle any changes to this Privacy Statement?
We may update this Privacy Statement from time to time as our services and privacy practices change, or as required by law. The effective date of our Privacy Statement is posted above, and we encourage you to visit our Site periodically to stay informed about our privacy practices. We will post the updated version of the Privacy Statement on our Site, and ask for your consent to the changes if legally required.
If you have questions or comments regarding this Privacy Statement or our privacy practices, please contact us at:
Embecta Corp.
1 Becton Drive
Franklin Lakes, New Jersey 07417-1880
Attention: Privacy Office
privacy-embecta@embecta.com