Willow Privacy Notice


Effective Date: January 1, 2023


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 ofJanuary 1, 2023 and can be found immediately below. The current version of the Privacy Notice, which will be in effect until December 31, 2022, can be found here.


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.


TABLE OF CONTENTS


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:

Contact Information

including your full name, email address, home address, and phone number.

Account Information

including username and password, and account configurations.

Product Information and Purchase Information

including your order history and billing and shipping address(es).

Payment Information

including credit or debit card number, expiration date, security code, and billing address. Please note we collect and process all financial information, such as credit card numbers, through third-party payment processing providers including Shopify and payment financing providers such as Affirm. As such, we do not retain any personally identifiable financial information in connection with your payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party payment processors or financing providers. Their use of your personal information is governed by their privacy notice. To view Shopify’s privacy policy, please click here. To view Affirm’s privacy policy, please click here.

Breast Pump Information

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.

Inquiry Information and Communications

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.

Feedback Information

including information provided in response to surveys or unsolicited feedback received regarding our Services.

Testimonial Information

including name and the testimonial statement regarding the Services.

Demographic Information

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).

Health Data

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).

Refer a Friend Program Information

such as your first name and your email address.

Sweepstakes, Giveaway, or Survey Information

such as your full name, email address, zip/postal code, and baby’s birthdate.

Coupon Information

such as email address, baby’s birthdate, and information about the product you are interested in.

Preferred Pricing Information

such as your full name, email address, employment information, date of birth, baby’s birthdate, baby’s due date, and expected return to work date. Note that all information collected through our preferred pricing program is collected through a third-party employment verification service, such as SheerID. Their use of your personal information is governed by their privacy notice. To view SheerID’s privacy policy, please click here.

Product Protection Plan Information

including the information collected when you purchase an optional product protection plan from Clyde on our website such as your email, phone number, and order ID. Note that all information collected through our preferred product protection provider, Clyde, is collected through Shopify and sent to Clyde when you purchase a product protection plan as part of your Willow product purchase. To view Clyde’s privacy policy please click here.

Affiliate and Creator Program Information

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.

Job Application 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.

Background Check 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.

Contact Information

including your full name, email address, home address, and phone number.

Account Information

including username and password, and account configurations.

Product Information and Purchase Information

including your order history and billing and shipping address(es).

Payment Information

including credit or debit card number, expiration date, security code, and billing address. Please note we collect and process all financial information, such as credit card numbers, through third-party payment processing providers including Shopify and payment financing providers such as Affirm. As such, we do not retain any personally identifiable financial information in connection with your payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party payment processors or financing providers. Their use of your personal information is governed by their privacy notice. To view Shopify’s privacy policy, please click here. To view Affirm’s privacy policy, please click here.

Breast Pump Information

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.

Inquiry Information and Communications

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.

Feedback Information

including information provided in response to surveys or unsolicited feedback received regarding our Services.

Testimonial Information

including name and the testimonial statement regarding the Services.

Demographic Information

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).

Health Data

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).

Refer a Friend Program Information

such as your first name and your email address.

Sweepstakes, Giveaway, or Survey Information

such as your full name, email address, zip/postal code, and baby’s birthdate.

Coupon Information

such as email address, baby’s birthdate, and information about the product you are interested in.

Preferred Pricing Information

such as your full name, email address, employment information, date of birth, baby’s birthdate, baby’s due date, and expected return to work date. Note that all information collected through our preferred pricing program is collected through a third-party employment verification service, such as SheerID. Their use of your personal information is governed by their privacy notice. To view SheerID’s privacy policy, please click here.

Product Protection Plan Information

including the information collected when you purchase an optional product protection plan from Clyde on our website such as your email, phone number, and order ID. Note that all information collected through our preferred product protection provider, Clyde, is collected through Shopify and sent to Clyde when you purchase a product protection plan as part of your Willow product purchase. To view Clyde’s privacy policy please click here.

Affiliate and Creator Program Information

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.

Job Application 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.

Background Check 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).


We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. For example, our Sites use Google Analytics, a web analytics service provided by Google LLC (“Google”), to collect and view reports about the traffic on our Sites. More information about the use of Google Analytics for these analytical and non-advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.


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:


Affiliates

We may receive personal information from other companies owned or controlled by Willow, and other companies owning or under common ownership with Willow. This includes any subsidiaries (i.e., any organization we own or control) or our parent company (i.e., any organization that owns or controls us) and any subsidiaries it owns.

Refer a Friend Program

We may receive your personal information such as name and email address when one of your friends refers you to our Services as part of the Refer a Friend program.

Service Providers

Our service providers that perform services solely on our behalf, such as email marketing providers, cloud providers, IT services, durable medical equipment sellers, employment verification providers, and payment processors, collect personal information and often share some or all of this information with us in connection with the facilitation of our Services.

Business Partners

When you engage in some of our promotions and sweepstakes that we collaborate in with third parties, we may receive your personal information from our business partners such as your email and promotion information in connection with the facilitation of the promotion or sweepstakes.

Social Media Platforms

When an individual interacts with us through various social media platforms, we may receive some information about the individual that they permit the platform to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the platform. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and platforms before sharing information with us or the social media platform.

Third Parties Related to Employment Applications

If you apply for a job by using the Greenhouse job application platform, we may receive information from your current or past employers, recruiters, third-party social media platforms and other third parties we use to obtain information about job applicants. To view Greenhouse’s privacy policy, please click here.

Information Providers

We may from time to time obtain information from third-party information providers from whom you have permitted to share your personal information, including marketing providers. We use this information to correct or supplement other personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with individuals.

Publicly Available Information

We may also collect personal information from publicly available sources, such as government records or publicly available websites, to supplement other personal information we collect.

Affiliates

We may receive personal information from other companies owned or controlled by Willow, and other companies owning or under common ownership with Willow. This includes any subsidiaries (i.e., any organization we own or control) or our parent company (i.e., any organization that owns or controls us) and any subsidiaries it owns.

Refer a Friend Program

We may receive your personal information such as name and email address when one of your friends refers you to our Services as part of the Refer a Friend program.

Service Providers

Our service providers that perform services solely on our behalf, such as email marketing providers, cloud providers, IT services, durable medical equipment sellers, employment verification providers, and payment processors, collect personal information and often share some or all of this information with us in connection with the facilitation of our Services.

Business Partners

When you engage in some of our promotions and sweepstakes that we collaborate in with third parties, we may receive your personal information from our business partners such as your email and promotion information in connection with the facilitation of the promotion or sweepstakes.

Social Media Platforms

When an individual interacts with us through various social media platforms, we may receive some information about the individual that they permit the platform to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the platform. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and platforms before sharing information with us or the social media platform.

Third Parties Related to Employment Applications

If you apply for a job by using the Greenhouse job application platform, we may receive information from your current or past employers, recruiters, third-party social media platforms and other third parties we use to obtain information about job applicants. To view Greenhouse’s privacy policy, please click here.

Information Providers

We may from time to time obtain information from third-party information providers from whom you have permitted to share your personal information, including marketing providers. We use this information to correct or supplement other personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with individuals.

Publicly Available Information

We may also collect personal information from publicly available sources, such as government records or publicly available websites, to supplement other personal information we collect.


HOW WE USE YOUR PERSONAL INFORMATION


  • We may use the personal information we collect 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 exercise or comply with our legal obligations or rights 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.


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:


Internally

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

Affiliates

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.

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 Notice.

Business Partners

At your direction, we may share your personal information with our third party business partners when you engage in a sweepstakes or co-promotion.

Data Analytics Providers

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.

Business Transaction or Reorganization

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.

Advertising Partners

We may share certain personal information collected through cookies with our advertising service providers and vendors in order to advertise our Services to you. For more information on how we collect and share this information, please see the Third-Party Data Collection and Online Advertising section of this Privacy Notice.

As Required or Permitted by Law

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.

With Your Consent

We will disclose your information where we have your consent to do so.

Internally

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

Affiliates

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.

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 Notice.

Business Partners

At your direction, we may share your personal information with our third party business partners when you engage in a sweepstakes or co-promotion.

Data Analytics Providers

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.

Business Transaction or Reorganization

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.

Advertising Partners

We may share certain personal information collected through cookies with our advertising service providers and vendors in order to advertise our Services to you. For more information on how we collect and share this information, please see the Third-Party Data Collection and Online Advertising section of this Privacy Notice.

As Required or Permitted by Law

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.

With Your Consent

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).


Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.


CONTROL OVER YOUR DATA

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. 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.


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 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.


CHILDREN’S PRIVACY

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.


THIRD-PARTY WEBSITES

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.


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.


CONTACT


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


REGION-SPECIFIC DISCLOSURES

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:


  • Canada: If you are resident of Canada, please click here for additional Canada-specific disclosures.
  • United States
    • Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please submit a request using the Consumer Privacy Rights Request Form.
    • Colorado, Connecticut, Utah, and Virginia: If you are a resident of the Colorado, Connecticut, Utah, and Virginia, please click here for additional disclosures.
    • California: If you are a resident of the State of California, please click here for additional California-specific disclosures.


ADDITIONAL PRIVACY INFORMATION FOR RESIDENT OF CANADA


These Additional Canada Privacy Disclosures (the “Canada Disclosures”) supplement the information contained in our Privacy Notice and apply solely to individuals located in Canada.


Unless otherwise expressly stated, all terms in these Canada Disclosures have the same meaning as defined in our Privacy Notice.


Your Consent

By submitting information to us in accordance with this Privacy Notice, we rely on your consent to collect, use and share your personal information, unless otherwise permitted under applicable laws. In some cases, your consent may be “implied”, meaning that your agreement is assumed based on your action or inaction at the point of collection, use or sharing of your personal information.


You may withdraw your consent to the collection, use or sharing of personal information at any time upon reasonable notice provided in writing, subject to legal or contractual restrictions. To withdraw your consent, please contact us at the email or postal address provided below under Contact. Withdrawing your consent may affect our ability to continue providing you with the Services where the continued use and disclosure of your personal information is necessary for the provision of the Services. Please note that even if you withdraw your consent, 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.


Your Privacy Rights

You have the right to request the access and correction of the personal information we hold about you in accordance with the laws applicable in the province or territory where you reside. If you have an account for our Services, you have the ability to view and modify certain information in your account (e.g., your contact information) through the account setting page or a similar option provided on the Services. You can otherwise exercise your rights by contacting us at the email or postal address provided below under Contact.


Personal Information Outside Canada

Willow is based in the United States and may use service providers located in various countries. As a result, personal information we collect as part of providing the Services may be stored or transferred to jurisdictions outside Canada and your personal information may be subject to the law of these jurisdictions, which may not provide the same level of protection as Canada. This may include laws permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in such jurisdictions. For further information regarding our policies and practices with respect to the use of non-Canadian service providers, please contact us as set out below.


Contact

If you have questions about these Canada Disclosures, please contact our privacy officer/person responsible for the protection of personal information at [email protected].


ADDITIONAL PRIVACY INFORMATION FOR RESIDENTS OF COLORADO, CONNECTICUT, UTAH, and VIRGINIA


In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have some or all of the following rights in respect of your personal information:


  • Right of Access: You may have the right to obtain:
    • confirmation of whether, and where, we are processing your personal information;
    • information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
    • information about the categories of recipients with whom we may share your personal information; and
    • copy of the personal information we hold about you.
  • Right of Portability: You may have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
  • Right to Rectification or Correction: You may have the right to obtain rectification or correction of any inaccurate or incomplete personal information we hold about you.
  • Right to Deletion or Erasure: You may have the right, in some circumstances, to require us to delete erase your personal information.
  • Right to Restriction: You may have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
  • Right to Opt-Out: You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of the use of your personal information for targeted advertising purposes, or to “sell” or “share” your personal information with third parties in certain contexts.
  • Right to Withdraw Consent: If you have provided consent for the processing of your personal information, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
  • Right to Appeal: In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.


Submitting Requests

  • To submit a request to exercise your right to know, right to access, or right to correction, please submit a request by using our contact form located here;
  • To submit a request to exercise your right to deletion, please submit a request by using our account deletion form located here;


Before processing your request, we will need to verify your identity and confirm you are of a state that offers such right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address or pump serial number.


In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.


To Exercise Your Opt-Out Rights

Unless you have exercised your Right to Opt-Out, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration or use your information for all the purposes described in this Privacy Notice, including for targeted advertising and certain profiling activities. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy policies.


You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal information so that we can authenticate you or properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. We may not process your request if we, in good faith, believe that the request is fraudulent. In such instances, we will send a notice to the requestor explaining our decision.


To exercise the Right to Opt-Out of personal information sharing for targeted advertising purposes or data “sales,” please click the link “Do Not Sell or Share My Personal Information” in our website footer to opt-out of targeted advertising from Willow. Please note this opt out is browser specific. You must reset your preferences if you clear cookies or use a different browser or device.


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, as amended by the California Consumer Privacy Rights Act (collectively, the “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:

  • Publicly available information.
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
  • Information excluded from the CCPA's scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.


Categories of Personal Information We Collect

In the last 12 months, we have collected the following categories of personal information from and about you:

  • Identifiers, such as full name, account name, mailing address, email address, and IP address.
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as phone number, mailing address, email address, account information, and payment information.
  • Protected Classification Characteristics, such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, veteran or military status, genetic information.
  • Commercial Information, such as service information and payment information including transactions history and insurance information if you use insurance to purchase a product.
  • Internet/Network Information, such as mobile device content, IP address, browsing history, and usage information.
  • Geolocation Information, such as your approximate location as determined though data like your IP address. Professional or Employment Information, such as the name and address of the company you work for in connection with job applications.
  • Sensory information, including recordings of calls with us, where permitted by law.
  • Other Personal Information, such as testimonial information, inquiry information, feedback information, demographic information (including information such as your due date, 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)), and any other personal information an individual chooses to provide us. We also collect health information such as 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).
  • Inferences, such as predictions about which services may be of interest to an individual.


In the last 12 months, we have collected the following categories of sensitive personal information:

  • Health Information, such as delivery method (i.e., natural or C-section), your pumping history, and how you are generally feeling (i.e., your mood or how are you sleeping).

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:

  • Identifiers, such as IP address.
  • Commercial Information, such as service information, including services of interest or orders made in connection with our services.
  • Internet/Network Information, such as log data (including operating system and browser type) and analytics data (including usage and activity on our website and online services)
  • Geolocation Data, such as general geographic location based on IP address.

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:


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 Access/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 specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information we have collected about you;
  • The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
  • The business or commercial purposes for collecting or, if applicable, selling personal information about you.

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 Correction

You have the right to request that any inaccuracies in your personal data be corrected, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data.

The Right to Opt-Out of Sales or Sharing of Personal Information

You have the right to direct us not to “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales or sharing.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct us to limit the use of your sensitive personal information to certain purposes, including to perform the services or provide the goods reasonably by an average consumer who requests those goods or services.

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 Access, Right to Know, Right to Deletion, or Right to Correction

  • To submit a request to exercise your right to know, right to access, or right to correction, please submit a request by using our contact form located here;
  • To submit a request to exercise your right to deletion, please submit a request by using our account deletion form located here;


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 or Sharing for Targeted Advertising

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.


You can also exercise the Right to Opt-Out of personal information “sales” to third parties for monetary or other valuable consideration, or opt out of the “sharing” of personal information to third parties for cross-context behavioral advertising purposes, please click the link “Do Not Sell or Share My Personal Information” in our website footer to opt-out of targeted advertising from Willow. Please note this opt out is browser specific. You must reset your preferences if you clear cookies or use a different browser or device. you may replace with you may


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:

  • For requests to know or delete personal information:
    • Receiving a power of attorney valid under the laws of California from you or your authorized agent; or
    • Receiving sufficient evidence to show that you have:
      • Provided the authorized agent signed permission to act on your behalf;
      • Verified your own identity directly with us pursuant to the instructions set forth in these CA Disclosures; and
      • Directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
  • For requests to opt out of personal information sales: Receiving a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.


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


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.


If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at [email protected]. We may not be able to modify or delete your information in all circumstances.


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.