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Privacy Statement

This Privacy Statement was last updated on March 23, 2022.

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Introduction

Scope

Summary of Key Points

Personal Data We Collect

Use of Personal Data

Sharing of Personal Data

Marketing Choices

Cookies

Data Subject Rights

Data Security

Cross-Border Data Transfers

California Consumers

Other Issues

Contact Us

Introduction and Purpose

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.

Scope

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.

 

What Personal Data Do We Collect?

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:

  • Identification data, such as full name, title and contact details;
  • Professional data, such as business name and type, business website, area of expertise, job title and description, department and professional experience;
  • Product data, such as types of product and services used or purchased by you or your employer and related data;
  • Communication and interaction details, such as customer service requests, correspondence, notes of calls or meetings and other customer care or technical service interactions;
  • Training data, such as details or product or clinical training received;
  • Health-related information, such as physical and medical information submitted through one of our platforms or on social media;
  • Financial or payment data (in limited cases only), such as bank account numbers and dates and amount of payments made or received; and
  • Other Site-specific data, as further detailed below.

 

Diabetes Care Application (“DC App”)

  • Registration and account details, including email address, password, status of consents, device ID (including manufacturer, device type and operating system version), language, country, time zone and IP address;
  • Health-related information, including physical, medical or health information submitted through the DC App; and
  • Automated data, including data obtained through tracking technologies, data from connected devices, location data, data sent to mobile devices and usage data.

How Do We Use Personal Data?

We use the above categories of Personal Data for the following purposes:

Purpose of Use

Categories of Personal Data

Delivering products and services, including
technical support and maintenance services

 

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
other communication with customers, end-users and other third parties

 

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
activities
, which may include profiling or
categorization of your potential interests in
embecta products and services for tailored
marketing

 

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
such as prevention of fraud, misuse of IT
systems or money laundering; physical
security; IT and network security; or internal
investigations

 

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
standards
, responding to and complying
with requests and legal demands from
regulators or other authorities in or outside
of your home country, compliance with
transparency laws governing interactions
with healthcare professionals and equivalent
laws and regulations, industry standards and
codes, details of training
given to distributors and other
intermediaries relating to compliance

 

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

How Do We Share Personal Data?

We share with or disclose Personal Data to the following categories of recipients:

  • Within embecta: We share Personal Data within the embecta group of companies as necessary for the purposes described above.
  • Service providers: We share Personal Data with service providers to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above, such as marketing, identity management, troubleshooting, data management, security and web hosting. We require service providers to provide reasonable security for Personal Data and to use and process such Personal Data on our behalf only at our instruction.
  • Auditors and advisors: We share Personal Data with auditors for the performance of audit functions and advisors for the provision of legal and other advice.
  • Business reorganization: We share Personal Data with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of embecta.
  • Mandatory disclosures and legal rights: We share Personal Data in order to comply with any subpoena, court order or other legal process, or other governmental request. We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

Marketing Choices

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.

Cookies

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:

  • Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

  • Analytical/Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance. We use Google Analytics, and you can see below for how to exercise choice regarding such cookies by visiting https://tools.google.com/dlpage/gaoptout.

  • Functional Cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Site. You can delete these cookies via your browser settings.

  • Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and Internet device. If you do not allow these cookies, you will experience less targeted advertising. You can delete these cookies via your browser settings. To learn more about certain cookies used for interest-based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising AllianceNetwork Advertising InitiativeDigital Advertising Alliance-CanadaEuropean Interactive Digital Advertising Alliance or your device settings.

  • Social Media Cookies: These cookies are set by a range of social media services that we have added to the Sites to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.

 

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.

Data Subject Rights

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.

Data Security

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.

Cross-Border Data Transfers

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.

California Consumers

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:

  • Identifiers;

  • Commercial information;

  • Professional or employment-related information;

  • Internet or other electronic network activity information;

  • Geolocation information; and

  • Protected classifications under California or federal law in certain limited cases.

 

Sources. As detailed above, we collect certain categories of CA Personal Information either directly from you and other third parties, including:

  • Your employer or the healthcare institution you work for;

  • Third party applications (including blogs, chat rooms, or support centers);

  • Advertising networks; and

  • Other companies or organizations.

 

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.

Other Issues

(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.

Contact Us

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@bd.com