Privacy Notice – February 24 2021

Privacy Policy

Effective Date: February 24, 2021

California residents: Click here to see our privacy information for California residents.

This Willow®* Pump, App and Website (together, the “Services”) are made available to assist you in your breastfeeding journey and it is our intention to provide a much needed solution to your needs as well as a relatable communication tool. We at Willow (“we,” “us,” “our”) have provided this Privacy Policy to help you better understand how we collect, use and store your information. Since technology and privacy laws are always changing, we may occasionally update this Privacy Policy. If a significant change is made, we will be sure to post a notice in your account. If you continue to use the Services after these changes are posted, you agree to the revised policy. The amended Privacy Policy supersedes all previous versions of agreements, notices or statements about the Privacy Policy. In order to use our App, you must register for the App.

This Privacy Policy is incorporated into and made part of our Terms of Service. We encourage you to review our Terms of Service, because they contain important information about your use of our Services.

Please read the following to learn more about our privacy policy.

1) WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of the information that we gather when you access or use the Services and upload data from your Willow Breast Pump to the Services. It also applies to information collected offline, such as the data we collect through questionnaires and forms. This Policy does not apply to the practices of entities that we do not own or control, individuals that we do not employ or manage, or other websites or digital services to which this Policy does not link.

2) WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?

We may collect the following types of information from you:

  • Information You Provide to Us:
    We may receive and store any information you provide to us. The types of information that we collect may include: your name, email address, address, phone number, and survey responses, product information such as your Willow Breast Pump name and serial number, usage information such as volume pumped and pump orientation, purchase information such as your order history and address, and if relevant, information about your medical insurance used to cover your purchase. You may also provide us with certain demographic information, including your age and gender. You can choose not to provide us with certain information, but then you may not be able to register with us or take advantage of all of the functionality of our Services.
  • Information We Automatically Collect:
    We may automatically collect information about your use of the Services, including, but not limited to, IP address, device type and model, operating system, unique device identifier, unique user ID, geo-location, browser type, frequency of use, volume pumped, crash reporting, website and app pages visited, and navigation through those pages. To learn more about the Data Collection Technologies we use to automatically collect this data, please see the section below titled “Data Collection Technologies.”
  • Online Forms and Support:
    If you complete an online form or you engage with our Support, we will ask you to include information about yourself in order to help resolve your issue. You understand that providing your information over the Internet involves some risk, and understand that in order to receive the support you are requesting, you are accepting that risk. Further, when you seek support from us, you understand and acknowledge that the individual(s) providing you with support may need to access your information to address the problem you are seeking support for; in this case, this information will only be used to help provide you with support.
  • Email, Text Messages, and Marketing Communications:
    You may receive emails or text messages regarding your use of the Willow Breast Pump. If you do not want to receive marketing emails, text messages, or other communications from us, unsubscribe from our marketing emails by following the link provided at the bottom of each email, responding “STOP” to text messages, or informing a Customer Care agent that you wish to be removed from our contact list. Please note that if you have opted out of receiving email or other messages from us, we may still need to contact you, but only with regard to the status of your account and other important administrative announcements. You cannot opt-out of these messages.
  • Information We Collect from Other Sources:
    We sometimes collect demographic and other information about you from public sources, advertisers and partners and combine such information with other information we collect from and about you.

    How we use this information:

    The information we gather from you enables us to (i) personalize and improve our Services, (ii) allow you to set up an account and profile that can be employed to use our Services, (iii) provide you with information, updates, offers and other communications related to our Services, (iv) analyze and report on the functioning of the Services in an aggregate manner for the benefit of our partners and (v) support your use of the Services.

3) DO WE SHARE YOUR INFORMATION?

We do not share your information, except with your consent or as disclosed in this Privacy Policy. We may share your information under the following circumstances:

  • Service Providers:
    We may share your information with companies with which we contract with to work on our behalf to help us deliver the Services and certain business functions, such as email management, credit card processing, order fulfillment, technology hosting, analytics, and collecting data through the use of other companies and then combining that data to create a profile. We take steps to ensure that our service providers will provide a similar level of protection for your information as is described in this Privacy Policy.
  • Business Transaction:
    We may sell, transfer or otherwise share some or all of our assets to a third party in connection with a merger, acquisition, reorganization, sale of assets or similar transaction, or in the event of bankruptcy. In such event, your information may be transferred to that third party.
  • As Required or Permitted by Law:
    We may disclose your information as we, in our sole discretion, believe necessary or appropriate to: respond to claims and legal process (including, but not limited to, subpoenas); protect the property and rights of Willow or a third party; protect the safety of the public or any person; prevent an activity that may be illegal, unethical or legally actionable; or otherwise to comply with law.
  • With Your Consent:
    We will disclose your information where we have your consent to do so.

    Please note that we may aggregate or de-identify the information we collect from and about you such that it can no longer be tied directly to you or your device. Such aggregated and/or de-identified data can be used and disclosed freely by us in our discretion.

4) DATA COLLECTION TECHNOLOGIES

We (and third parties acting on our behalf) use data collection technologies that help us manage the operation of the Services and track usage behavior so that we can make your use of the Services more enjoyable.

Our data collection technologies include:

  • Cookies:
    Cookies are text files containing small amounts of information that are stored on your computer or mobile device’s browser directory. Cookies are created when you visit a website that uses cookies to keep track of your movements within the website. Cookies are useful because they allow us to recognize your device, remember your preferences, automatically log you in to your account, and provide us with information that we can use to further personalize your user experience. You can find more information about cookies at www.allaboutcookies.org.
  • Web beacons and GIFs:
    Certain pages on the Website contain web beacons (also known as web bugs, pixel tags and clear GIFs), which we use to monitor how users use the Website. We use web beacons in combination with Cookies to understand how our users navigate through and process the content contained on our Website.
  • Local Storage and Local Shared Objects:
    We use local shared objects (LSOs) such as Flash Cookies and local storage, such as HTML5 Local Storage, to enhance user experience by, for example, storing your user preferences and settings (e.g., volume/mute) in connection with animated content on the Services. Local storage is similar to browser cookies but can store data more complex than simple text. By itself, local storage cannot do anything to or with the data stored on your device. Like cookies, local storage can only access personal data that you have provided on the Services. Third parties with whom we partner to provide certain features on the Services or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

Your browser may allow you to manage your cookies and local storage. Because each browser is a little different, we encourage you to check your browsers’ “Help” feature to learn how to block cookies, how to receive notification of new cookies, and how to disable existing cookies. For more information about managing cookies, please visit www.allaboutcookies.org/manage-cookies/.

Online Advertising: We may engage third parties to serve targeted advertisements on our behalf. We have implemented third party tracking tools including Google Analytics and Facebook Tools and these entities may use Data Collection Technologies to collect information about your activity on our Services and your interaction with our advertising in order to determine which ads you see on third-party websites and applications. These tools and services place cookies, web beacons and other devices or technologies on our Services or your device to enable them to track traffic data and to access and log any information from web browsers concerning web activities immediately prior to using our Services. The data collected typically includes information such as your IP address, your Internet Service Provider, your web browser, the time spent on webpages, the links clicked and the advertisements viewed on those pages. We may share with third parties and third parties may employ certain pieces of aggregated, non-personal information to compile statistics, metrics, insights and general trend data about third party services for, among other things, third party marketing and promotional purposes. For more information about behavioral advertising and to understand your options, including how to opt out of receiving these tailored advertisements, please visit www.aboutads.info/choices. You can opt out of Google Analytics through its currently available opt-outs for the web. Please note that when you opt out, you may still see advertisements; however, they will not be targeted based on your interests.

Do Not Track Signals: Some web browsers incorporate a “do-not-track” (“DNT”) or similar feature that signals to websites with which the browser communicates that a visitor does not want to have his/her online activity tracked. If a website receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, Willow (along with many other website operators) does not currently respond to DNT signals. For more information about DNT signals, visit allaboutdnt.com.

Geolocation Tracking

Some components of the Services may include a geo-tracking feature that allows us to offer you location-based services. You can change your preferences on your mobile device and/or browser to deny us access to your geolocation. Please note that if you disable geolocation tracking, certain features of the Services may not be available to you.

5) IS INFORMATION ABOUT ME SECURE?

Your account is protected by a password for your privacy and security. You can help prevent unauthorized access to your account and the information stored therein by selecting and protecting your password appropriately and limiting access to your computer, mobile device, and browser by signing off after you have finished accessing your account.

We endeavor to protect your information to ensure that it is kept private, and we employ a variety of physical, technical, and administrative security measures. However, we cannot guarantee the security of such information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of your information at any time.

6) WHAT INFORMATION CAN I ACCESS OR DELETE?

We allow you to access certain categories of information that we maintain about you for the purpose of viewing, and in certain situations, updating or deleting that information or revoking consent for collecting that information. These categories may change as our Services change. Any information that is automatically uploaded from a Willow Breast Pump to the Services cannot be later changed or updated.

Certain information is required to access some of our Services, so your deletion of certain information, or provision of inaccurate information, may render the services inoperable, in whole or in part. When you update information, however, we often maintain a copy of the unrevised information in our private records. Please note that we may continue to use aggregate and/or de-identified data derived from your information after you have requested it to be modified or deleted.

If you are a California resident, please also see the “Additional Privacy Information for California Residents” section below for more information about your privacy choices and rights under California law.

7) DATA RETENTION

As a general matter, we retain your information for as long as you keep an account with us. You may request deletion of certain types of usage information by emailing [email protected]. In certain situations, we will delete your information after it is no longer needed to provide a feature or service. We also keep information, including information submitted by individuals without an account, for as long as necessary for our legitimate business interests and/or as needed or permitted for legal reasons.

8) CHILDREN’S PRIVACY

The App is not directed to children under the age of 13, and Willow does not knowingly collect any ”personal information” (as such term is defined in the U.S. Children’s Online Privacy Protection Act” or “COPPA”) from children under 13 without the verifiable consent of that child’s parent or guardian. If you are aware of a child providing his or her personal information without parental consent, please contact us at [email protected]. We will endeavor to delete all data we collected from a child under 13 if we discover we collected it without that child’s parental consent.

9) ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

A. Categories of Personal Information We Collect

Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we collect are:

  • Contact Information (such as name, phone number, address, email address);
  • Login Information (such as your account name and password);
  • Financial and commercial Information (such as transactions history and insurance information if you use insurance to purchase a product);
  • Demographic information (such as your gender and age)
  • Professional or Employment Information (such as the name and address of the company you work for in connection with insurance requests);
  • Geolocation Information (such as your precise or approximate location as determined though data like GPS or IP address);
  • Device and Online Information (such as mobile device content, IP address, browsing history, and usage information);

B. How we source, use, and share these categories of personal information.

We source, use, and share the categories of personal information we collect from and abut you consistent with the various business and operational purposes we discuss throughout this Privacy Policy and for the business and operational purposes of our service providers in accordance with the CCPA. See the “What Information Do We Collect and For What Purpose?,” and “Do We Share Your Information?” sections above for more information.

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months from the effective date of this Policy.

Your California Privacy Rights.

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
  • Provide access to and/or a copy of certain personal information we hold about you.
  • Delete certain personal information we have about you.
  • Provide you with information about the financial incentives that we offer to you, if any.

The CCPA further provides you with the right not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you. If you would like further information regarding your legal rights under California law or would like to exercise any of them, or if you are an authorized agent making a request on a California consumer’s behalf, please contact us at [email protected] or by using our contact form located here.

Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

California Notice to Minors: If you are a California resident under age 18, you may request that we remove any user contribution that you publicly posted on the App. We will make a good faith effort to delete or remove your user contribution from public view as soon as reasonably practicable; however, we may be required by law to not remove or allow removal of your user contribution. To request removal of your user contribution, please send an email with a detailed description of your user contribution to [email protected]. We reserve the right to request that you provide information that will enable us to confirm that you created and posted the user contribution you want removed.

10) A NOTE TO INTERNATIONAL USERS

Willow and our servers are located in the United States and subject to U.S. law. If you are accessing the App from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the law of your jurisdiction. By accessing and using the App, you consent to the transfer to and processing of your Personal Information in the United States.

11) WHO CAN I CONTACT WITH A PRIVACY QUESTION?

If you have questions or concerns regarding this policy, please contact us at [email protected].

* Note: Willow is a d/b/a of Exploramed NC7, Inc.