Privacy Notice – November 5, 2021

Privacy Policy

Effective Date: November 5, 2021


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


This Willow®* Pump, along with any associated mobile applications and websites that link to this Privacy Policy (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 provide you with notice. If you continue to use the Services after these changes are posted, you agree to the revised Privacy Policy. The amended Privacy Policy supersedes all previous versions of agreements, notices or statements about the Privacy Policy. In order to use our mobile applications, you must register for those applications.


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.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of the information that we gather when you 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 Privacy 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 Privacy Policy does not link.

INFORMATION WE COLLECT

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 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: your name, email address, home 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 billing and shipping 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, and other information, such as your due date and anticipated return-to-work date. If you interact with us on social media, we may collect information you share with us through those interactions. 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:
    When you interact with the Services, we may automatically collect information about your browser, device, and use of the Services, including, but not limited to, IP address, device type and model, operating system, unique device identifier, Internet service provider, cookie identifiers, automatically-generated unique user ID, other device or online identifiers, geo-location, browser type, frequency of use of the Services, volume pumped, web logs, crash reporting, website and app pages visited, and navigation through those pages. Some of this data is collected using cookies and similar technologies. To learn more about these technologies and your choices regarding them, please see the section below titled “Your Data Choices.”

  • 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. We may also collect certain medical and insurance information if you use insurance to purchase a product. 

HOW WE USE YOUR INFORMATION

We may use the information we gather to:

  • Provide, maintain, and improve our Services;
  • Allow you to set up an account and profile that can be employed to use our Services;
  • Provide customer support and respond to your questions or requests;
  • Personalize the Services, including by providing custom content;
  • Provide you with information, updates, offers and other communications related to our Services, subject to any opt-out preferences you have communicated to us;
  • Research and analyze the functioning and use of the Services;
  • Process orders and payments;
  • Verify your identity and prevent fraud;
  • In accordance with applicable legal requirements, advertise and market our Services to you, including on third-party websites (subject to any opt-out preferences you have communicated to us);
  • To comply with legal requirements and our policies; and
  • To protect the safety, rights, property or security of Willow, our users, employees, third parties, members of the public and/or our Services.
  • We may also use the information we collect for any other purpose with your consent.

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.

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information. Our legal bases for processing your information as described in this Privacy Policy are as follows:

  • Where use of your information is necessary to perform our obligations under a contract or commitment to you. For example, to provide the services you’ve requested from us, or to comply with our Terms of Service.
  • Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Services, operate our business and our Services, make and receive payments, defend our legal rights, and prevent fraud.
  • Where we use your information to comply with applicable legal obligations. For example, keeping track of purchases for tax and auditing purposes.
  • Where you have consented to our processing of your information for a particular purpose.

For the purposes discussed in this Privacy Policy, 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 Policy.

HOW WE SHARE YOUR INFORMATION

We may share your information under the following circumstances:

  • Internally
    We may share your information with Willow employees and contractors to provide you with the Services, provide customer support, and for similar purposes.

  • 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, 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 Policy.

  • Affiliates and Business Transaction:
    We may share information among our affiliates for business purposes. 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.

  • Advertising
    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 “Your Data Choices” for your choices regarding how we share information in this way.

  • 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, 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.

  • With Your Consent:
    We will disclose your information where we have your consent to do so. 

YOUR DATA CHOICES

Cookies and Similar Technologies. When you interact with the Services, we (and third parties acting on our behalf) may automatically collect certain information about your browser, device, and use of the Services through cookies, pixel tags, web beacons, local storage, and other similar technologies.

  • Cookies are small text files stored on your browser or device, which allow us to provide certain features of the Services, personalize your user experience, and advertise our Services to you. You can find more information about cookies at www.allaboutcookies.org.

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 browser’s “Help” feature to learn how to manage cookies. For more information about managing cookies, please visit www.allaboutcookies.org/manage-cookies/. Please note that if you block or otherwise reject cookies or other similar technologies, certain features of the Services may not function as expected.

Tailored Advertising: We may engage third parties to serve tailored advertisements for our Services on our behalf on third-party websites and applications. You have certain choices about how your information is used for this purpose.

  • For more information about tailored advertising or to opt out of participating companies, please visit the Digital Advertising Alliance’s (DAA) opt-out program at www.aboutads.info/choices or the Network Advertising Initiative’s (NAI) opt-out page at  https://optout.networkadvertising.org/ . We make no representation about the accuracy or effectiveness of these opt out mechanism. You. 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 tailored based on your interests.
  • Some tailored advertising is carried out using cookies. You may be able to set your browser to refuse certain types of cookies, or to alert you when they are being used. Please consult the “Help” section of your browser for more information. However, if you block or otherwise reject cookies or other similar technologies, certain websites (including our Services) may not function as expected. Because we and third parties may use non-cookie technologies with your browser or device, browser settings that block cookies used in isolation may not affect the functioning of those technologies.
  • Mobile devices often include settings to help you manage how your device collects and shares information for advertising purposes.  For more information on how to manage those devices settings, please visit the Network Advertising Initiative’s mobile choice page at https://www.networkadvertising.org/mobile-choice.
  • Please note: modifying your mobile device or browser settings, or opting out of interest-based advertising using your web browser, may have different results depending on the type of device you are using, the type of web browser you are using, and the version of the device operating system you are running. Opting out of tailored advertising does not prevent you from seeing ads for our Services online; instead, the ads you see are not based on your interaction with the Services. Opting out is generally effective only on a device-by-device, or browser-by-browser basis. If you use more than one browser or device, the effect of any opt-out mechanism you use may be limited to the device on which you used the mechanism.


“Do Not Track” Signals: “Do-not-track” (“DNT”) is a setting offered by some browswers. 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 Policy).

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.

SECURITY

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 because no security measures are perfect..

WHAT INFORMATION CAN I ACCESS OR DELETE?

Depending on your jurisdiction of residence, you may have certain rights to access, delete, or correct your information. Your rights will be subject to applicable exceptions, and we will need to verify your identity before processing your request. If you would like to submit a request relating to your data, please email us at [email protected]

DATA RETENTION

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, for as long as necessary for our legitimate business interests and/or as needed or permitted for legal reasons.

CHILDREN’S PRIVACY

The Services are not directed to children under the age of 13, and Willow does not knowingly collect any ”personal information” (as 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.

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 Services 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 Services, you consent to the transfer to and processing of your information to the United States.

CONTACT

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

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of the information that we gather when you 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 Privacy 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 Privacy Policy does not link.

INFORMATION WE COLLECT

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 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: your name, email address, home 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 billing and shipping 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, and other information, such as your due date and anticipated return-to-work date. If you interact with us on social media, we may collect information you share with us through those interactions. 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:
    When you interact with the Services, we may automatically collect information about your browser, device, and use of the Services, including, but not limited to, IP address, device type and model, operating system, unique device identifier, Internet service provider, cookie identifiers, automatically-generated unique user ID, other device or online identifiers, geo-location, browser type, frequency of use of the Services, volume pumped, web logs, crash reporting, website and app pages visited, and navigation through those pages. Some of this data is collected using cookies and similar technologies. To learn more about these technologies and your choices regarding them, please see the section below titled “Your Data Choices.”

  • 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. We may also collect certain medical and insurance information if you use insurance to purchase a product. 

HOW WE USE YOUR INFORMATION

We may use the information we gather to:

  • Provide, maintain, and improve our Services;
  • Allow you to set up an account and profile that can be employed to use our Services;
  • Provide customer support and respond to your questions or requests;
  • Personalize the Services, including by providing custom content;
  • Provide you with information, updates, offers and other communications related to our Services, subject to any opt-out preferences you have communicated to us;
  • Research and analyze the functioning and use of the Services;
  • Process orders and payments;
  • Verify your identity and prevent fraud;
  • In accordance with applicable legal requirements, advertise and market our Services to you, including on third-party websites (subject to any opt-out preferences you have communicated to us);
  • To comply with legal requirements and our policies; and
  • To protect the safety, rights, property or security of Willow, our users, employees, third parties, members of the public and/or our Services.
  • We may also use the information we collect for any other purpose with your consent.

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.

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information. Our legal bases for processing your information as described in this Privacy Policy are as follows:

  • Where use of your information is necessary to perform our obligations under a contract or commitment to you. For example, to provide the services you’ve requested from us, or to comply with our Terms of Service.
  • Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Services, operate our business and our Services, make and receive payments, defend our legal rights, and prevent fraud.
  • Where we use your information to comply with applicable legal obligations. For example, keeping track of purchases for tax and auditing purposes.
  • Where you have consented to our processing of your information for a particular purpose.

For the purposes discussed in this Privacy Policy, 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 Policy.

HOW WE SHARE YOUR INFORMATION

We may share your information under the following circumstances:

  • Internally
    We may share your information with Willow employees and contractors to provide you with the Services, provide customer support, and for similar purposes.

  • 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, 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 Policy.

  • Affiliates and Business Transaction:
    We may share information among our affiliates for business purposes. 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.

  • Advertising
    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 “Your Data Choices” for your choices regarding how we share information in this way.

  • 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, 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.

  • With Your Consent:
    We will disclose your information where we have your consent to do so. 

YOUR DATA CHOICES

Cookies and Similar Technologies. When you interact with the Services, we (and third parties acting on our behalf) may automatically collect certain information about your browser, device, and use of the Services through cookies, pixel tags, web beacons, local storage, and other similar technologies.

  • Cookies are small text files stored on your browser or device, which allow us to provide certain features of the Services, personalize your user experience, and advertise our Services to you. You can find more information about cookies at www.allaboutcookies.org.

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 browser’s “Help” feature to learn how to manage cookies. For more information about managing cookies, please visit www.allaboutcookies.org/manage-cookies/. Please note that if you block or otherwise reject cookies or other similar technologies, certain features of the Services may not function as expected.

Tailored Advertising: We may engage third parties to serve tailored advertisements for our Services on our behalf on third-party websites and applications. You have certain choices about how your information is used for this purpose.

  • For more information about tailored advertising or to opt out of participating companies, please visit the Digital Advertising Alliance’s (DAA) opt-out program at www.aboutads.info/choices or the Network Advertising Initiative’s (NAI) opt-out page at  https://optout.networkadvertising.org/ . We make no representation about the accuracy or effectiveness of these opt out mechanism. You. 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 tailored based on your interests.
  • Some tailored advertising is carried out using cookies. You may be able to set your browser to refuse certain types of cookies, or to alert you when they are being used. Please consult the “Help” section of your browser for more information. However, if you block or otherwise reject cookies or other similar technologies, certain websites (including our Services) may not function as expected. Because we and third parties may use non-cookie technologies with your browser or device, browser settings that block cookies used in isolation may not affect the functioning of those technologies.
  • Mobile devices often include settings to help you manage how your device collects and shares information for advertising purposes.  For more information on how to manage those devices settings, please visit the Network Advertising Initiative’s mobile choice page at https://www.networkadvertising.org/mobile-choice.
  • Please note: modifying your mobile device or browser settings, or opting out of interest-based advertising using your web browser, may have different results depending on the type of device you are using, the type of web browser you are using, and the version of the device operating system you are running. Opting out of tailored advertising does not prevent you from seeing ads for our Services online; instead, the ads you see are not based on your interaction with the Services. Opting out is generally effective only on a device-by-device, or browser-by-browser basis. If you use more than one browser or device, the effect of any opt-out mechanism you use may be limited to the device on which you used the mechanism.


“Do Not Track” Signals: “Do-not-track” (“DNT”) is a setting offered by some browswers. 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 Policy).

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.

SECURITY

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 because no security measures are perfect..

WHAT INFORMATION CAN I ACCESS OR DELETE?

Depending on your jurisdiction of residence, you may have certain rights to access, delete, or correct your information. Your rights will be subject to applicable exceptions, and we will need to verify your identity before processing your request. If you would like to submit a request relating to your data, please email us at [email protected]

DATA RETENTION

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, for as long as necessary for our legitimate business interests and/or as needed or permitted for legal reasons.

CHILDREN’S PRIVACY

The Services are not directed to children under the age of 13, and Willow does not knowingly collect any ”personal information” (as 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.

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 Services 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 Services, you consent to the transfer to and processing of your information to the United States.

CONTACT

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

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


We collect the following categories of personal information from and about you:


  • 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 use and share these categories of personal information


We use the above categories of personal information for the business and operational purposes of us and our service providers in accordance with the CCPA. See the “Information We Collect” and “How We Use Your Information,” and “How We Share Information” sections above for more information.


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 hold 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.