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Effective Date: September 5, 2022
We have updated our Privacy Notice to better reflect the ways in which we collect, use, and share your personal information. The new Privacy Notice will be effective as of September 5, 2022 and can be found immediately below. The current version of the Privacy Notice, which will be in effect until September 5, 2022, can be found here.
California residents: Click here to see our privacy information for California residents.
Welcome! Willow (“Willow”, “we”, “our, or “us”) is here to assist you with your motherhood journey and it is our intention to build solutions to mom’s most meaningful problems. We at Willow have drafted this Privacy Notice to help you better understand how we collect, use, and otherwise process your personal information in connection with the Willow 3.0 Pump and Willow Go Pump (collectively, “Willow Pump”), any associated mobile applications and our websites that post or link to this Privacy Notice, including https://onewillow.com/ (collectively, the “Site”), and our services offered in connection with the Site, (collectively with the Willow Pump and the Site, the “Services”). Note this Privacy Notice does not address our privacy practices relating to Willow employees and other personnel.
We encourage you to review our Terms of Service, because they contain important information about your use of our Services.
PERSONAL INFORMATION WE COLLECT
Sometimes we collect personal information automatically when an individual interacts with our Services and sometimes, we collect personal information directly from an individual. At times, we may collect personal information about an individual from other sources and third parties, even before our first direct interaction.
Personal Information You Provide to Us:
We may collect any personal information you provide to us when, for example, you sign up for an account, interact with customer support, or input information into the Services. The types of information that we collect may include:
including your full name, email address, home address, and phone number.
including username and password, and account configurations.
including your order history and billing and shipping address(es).
including Willow Pump name and serial number; usage information such as volume pumped, suction functionality, session duration, start and end times, battery life, Bluetooth connection status, charge information, paring information, pump resets, session rating, and pump orientation.
such as the content of emails, texts, or other communications with us. This information may include your full name, email address, Willow Pump serial number, and any other information you choose to provide to us. This also includes information provided in order to subscribe to any of our newsletters or waitlist (such as email address) or contact information provided on our Services.
including information provided in response to surveys or unsolicited feedback received regarding our Services.
including name and the testimonial statement regarding the Services.
including your age and gender, household demographics, and other information, your baby’s birth date, your return-to-work plan, your anticipated return-to-work date, your feeding plan (i.e., breastfeeding, formula), and your baby’s name(s).
such as your delivery method (i.e., natural or C-section), your pumping history, and how you are generally feeling (i.e., how is your mood or how are you sleeping).
such as your first name and your email address.
such as your full name, email address, zip/postal code, and baby’s birthdate.
such as email address, baby’s birthdate, and information about the product you are interested in.
including the information collected when you apply to be part of our Affiliate or Creator program such as full name, email address, phone number, address, website information (including language, URL, and content), username, password, direct deposit information (including bank name, bank city and state, name on the account, account number, and routing number), sale information, commission and lead information, and feedback information.
including your full name, email address, phone number, resume, cover letter, immigration status, state/province/territory of residence, gender, race, and any additional information you choose to provide to us such us your linked profile.
Where an individual chooses to contact us, we may need additional information to fulfill their request or respond to their inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request or the personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information the individual provides at that time.
Personal Information We Automatically Collect:
As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions and website usage patterns automatically when visiting or interacting with our Services, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Services and any errors that may occur during the visit to our Services), analytics data (such as the electronic path taken to our Services, through our Services and when exiting our Services, as well as usage and activity on our Services); device data, (such as device language and settings, battery life, Bluetooth connection status, pairing information, reset information); and location data (such as general geographic location based on the log data we or our third-party providers collect).
To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Services, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
For more information on our and third-party partners’ data collection and online advertising practices, please see the Third Party Data Collection and Online Advertising section of this Privacy Notice.
Personal Information We Collect from Other Sources:
We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from individuals.
We receive the same categories of personal information as described above from the following sources and third parties:
HOW WE USE YOUR PERSONAL INFORMATION
We may use the personal information we collect to:
We may aggregate, de-identify and/or anonymize any information collected through the Services so that such information is no longer reasonably capable of being associated with you. We may use aggregated or anonymized information for any purpose, including for research and marketing purposes, and we may also share such information for any purpose with any third parties, at our discretion.
For the purposes discussed in this Privacy Notice, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Notice.
HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your personal information under the following circumstances:
We may share your personal information with Willow employees and contractors to provide you with the Services, provide customer support, and for similar purposes.
We may share your personal information among our affiliates, including other companies owned or controlled by Willow and other companies owning or under common ownership with Willow, for business purposes.
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, legal or tax services, technology hosting, and analytics (“Service Providers”). 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 Notice.
At your direction, we may share your personal information with our third party business partners when you engage in a sweepstakes or co-promotion.
We share information with data analytics providers who analyze statistics and trends relating to the usage of and activity relating to the Services. These data analytics providers produce reports and make suggestions for our customer and business strategy based on the personal information and other information analyzed.
We may also share your information if we 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, or in diligence leading up to a potential corporate transaction. We may disclose personal information to a third party during negotiation of, in connection with, or as an asset in such a corporate business transaction in accordance with applicable laws.
We may share your information with advertising service providers and vendors in order to advertise our Services to you. Please see the section below titled “Control Over Your Data” for your choices regarding how we share information in this way.
We may disclose your personal 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, rights and safety of Willow, our employees and customers, and any third party; prevent an activity that may be illegal, unethical or legally actionable; or otherwise to comply with the law.
We will disclose your information where we have your consent to do so.
THIRD-PARTY TRACKING AND ONLINE ADVERTISING
We may share, or we may permit third-party online advertising networks, social media companies, and other third-party services, to collect information about your use of our Site over time so that they may play or display ads that may be relevant to your interests on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, clickstream information, browser type, time and date you visited the website and other information. This information is used to display targeted ads on or through our Services or on other websites, apps, or services. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. We may also display targeted advertising to you through social media platforms, such as LinkedIn, Facebook, TikTok, Twitter, Google, Pinterest, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.
Google Analytics and Advertising.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our Services.
You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/ (for U.S. users) or http://youradchoices.ca/ (for Canadian users). You can also opt-out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices (for U.S. users) or https://youradchoices.ca/en/appchoices (for Canadian users). You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest-based ads" (Android).
CONTROL OVER YOUR DATA
"Do Not Track" Signals: "Do-not-track" ("DNT") is a setting offered by some browsers. DNT signals are not yet uniform, so Willow, like many other website operators, does not currently recognize or respond to DNT signals.
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.
Social Media: To control the information you share with us when you follow us, like our posts, or otherwise interact with us on social media, you can adjust your social media account settings related to how your information is shared.
Marketing Communications: If you receive marketing emails from us, you may unsubscribe at any time by following the instructions contained within the email. Note that you may continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services and using the unsubscribe link will not halt those communications (for example, communications regarding our Services or updates to our Privacy Notice).
Push Notifications: If you opt in to receive push notifications, we will send you push notifications. If you no longer wish to receive these types of communications, you may turn them off through your device settings.
Modifying Account Information. If you have an account for our Services, you have the ability to modify certain information in your account (e.g., your contact information) through the account setting page or a similar option provided on the Services. If you have any questions about modifying or updating any information in your account, please contact us at the email or postal address provided below.
Deletion. If you ever want to delete your account, you may do so at any time by contacting us at the email provided below or here. Please note we may retain some personal information for certain legal, security, and business needs. For example, we’ll retain information about any purchases you may have made through the Services, and about when you accepted our Terms of Service.
As a general matter, we retain your information for as long as you keep an account with us. 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 and information about individuals who no longer have an account, for as long as necessary for our legitimate business interests and/or as needed or permitted for legal reasons.
The Services are not directed to children under the age of 16, and Willow does not knowingly collect any personal information from children under 16. If you are aware of a child providing his or her personal information, please contact us at [email protected]. We will endeavor to delete all data we collected from a child under 16 if we discover we collected it.
The Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy policies.
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions, or states. Please refer below for disclosures that may be applicable to you:
CHANGES TO THIS PRIVACY NOTICE
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
If you have questions or concerns regarding this Privacy Notice, please contact us at [email protected].
Additional Privacy Information For California Residents
These Additional California Privacy Disclosures (the "CA Disclosures") supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California ("consumers").
These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 ("CCPA").
Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
Scope of Disclosures
When we use the term "personal information" in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include information that is made publicly available from government records, that is deidentified or aggregated such that it is not reasonably capable of being associated with an individual, or that is otherwise excluded from the CCPA's scope.
For the purposes of these CA Disclosures, personal information does not include:
Categories of Personal Information We Collect
In the last 12 months, we have collected the following categories of personal information from and about you:
We collect this information directly from individuals, their browser or device when they interact with our services, our affiliates, an individual’s employer, our service providers and business partners, social media and professional networks, information providers and other publicly available sources. For more information about the personal information that we collect and how we collect it, please refer to the Personal Information We Collect section of our Privacy Notice.
How We Use Personal Information
We use the above categories of personal information for a variety of purposes. For example, we use personal information to communicate with customers about our services, to provide customers with our services, to facilitate partner integrations, to process payments, and to otherwise operate our business. For more information about our use of Personal Information, please refer to the How We Use Personal Information section of our Privacy Notice.
Disclosure and Sale of Personal Information
As further described in the How We Share Your Personal Information section of our Privacy Notice, we disclose personal information to third parties for business purposes.
Disclosure for Business Purposes
In the last 12 months, we have disclosed for business purposes all categories of personal information outlined above to the following categories of recipients: Affiliates, Employers, Data Analytics Providers, Marketing Partners, Business Partners, Service Providers, and certain other third parties where individuals have provided consent or direction, or where we are complying with law or protecting our rights (such as to our legal advisors).
Sale of Personal Information
As is common practice among companies that operate online, in the last 12 months, we have allowed certain third-party providers to collect information about consumers directly through our website and other online services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. As a result of this practice, in the last 12 months, we have sold the following categories of personal information to these third-party providers, subject to each consumer’s settings and their right to opt-out:
Since our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16, we do not sell personal information of consumers we know to be under the age of 16.
For more information about how we otherwise disclose personal information, please refer to the How We Share Your Personal Information section of our Privacy Notice.
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:
The Right to Know
You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:
The Right to Request Deletion
You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of the rights described above.
However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
"Shine the Light"
California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California's "Shine the Light" law (Civ. Code § 1798.83).
How to Exercise Your California Privacy Rights
To Exercise Your Right to Know or Right to Deletion
Please submit a request by:
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information identified in our Privacy Notice, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.
To Exercise Your Right to Opt Out of Personal Information Sales
As is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third party businesses to collect and disclose your personal information (including preferences, geolocation, commercial information and internet, network and device information) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use this information for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell that information to other businesses for advertising and other purposes. By visiting here, you can opt out from sales of this type of personal information by businesses that participate in the opt-out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA's CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices. To learn more about how third parties collect information through tracking technologies and what other choices you may have in relation to those activities, please see Third Party Tracking and Online Advertising section of our Privacy Notice.
To Submit a Request as an Authorized Agent
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf by:
We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.
Minors Under Age 16
We do not and will not "sell" the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.
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.
November 5, 2021
February 24, 2021
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