This Policy governs the collection, processing and use of your personal data and the use and disclosure of your protected health information, when you visit and/or interact with our Website, and explains our practices with respect to the placement of cookies, including the types of cookies we use and how you can manage them.
By clicking the “I agree” button or by otherwise visiting or accessing the Website or using any of the services provided, you agree to the terms of this Policy.
This Policy was last revised on July 1, 2020.
1. Collection, Processing and Use of Your Personal Data
1.1 Anonymous Usage of our Website
You are welcome to visit our Website while remaining anonymous and without revealing any of your personal data by using one of the opt-out mechanisms described herein.
However, when you first visit our Website we will display a cookie banner informing you how we will be placing cookies on your device and tracking your website usage behavior. This helps us to better understand how our customers use our Website and to improve our website offering and services, which includes providing you with a more personalized website experience and targeted offers. In case you have registered on our Website, including but not limited to by registering for “The Mom’s Room” or “Join our Community” or otherwise provided your consent on our Website to receive marketing communications (see Section 2 below), we will use such website usage information also to provide you with more personalized communications reflecting your specific interests and preferences. Please see Sections 2.2, 2.4 and 2.5 below for a detailed description of the cookies and website analysis tools we use for this purpose and your rights to change your choices.
If you do not agree with the above practices and wish to remain fully anonymous, you can indicate not to provide your consent, or withdraw your consent with effect for the future, by using the opt-out mechanisms available (see Sections 2.2, 2,3, 2.4 and 2.5 below). In this case, we will only collect certain anonymous information which do not directly relate to your person. For example, we may collect the number of visitors to our Website, browsing patterns and areas of interest. We analyze this information to understand how our customers use our Website, and to assess trends, statistics and our customers’ needs, which help us to improve our Website and to better serve our customers.
Other than as indicated above, we will only collect your personal data if you voluntarily decide to share such information with us, such as by sending an inquiry (via email, chat or other means) or requesting a specific service. Unless you have provided your explicit consent, and unless indicated otherwise in this Policy, we will use the personal data that you have shared with us only as necessary for enabling your use of our Website, handling your requests and providing the requested services or goods. Apart from that, we may use any personal data we receive only in anonymized form (i.e., in a non-personally identifiable form which does not allow for any conclusions as to your identity) for statistical purposes and for internal evaluation to improve our products and services. Your data will not be processed for other purposes or beyond the scope of this Policy, except where expressly permitted or required by applicable law
1.2 Website Consent and Registration
In using our Website or by registering on our Website, we may ask for your consent to receive marketing communications. For example, you may register on our Website for “The Mom’s Room” or “Join our Community” or you may register your Medela breast pump. When doing so we will ask you for your consent to send you marketing communications. By providing your consent, you agree to receive marketing communications from Medela and other third parties and you agree to us sharing your personal information with third parties for marketing purposes. As part of your consent, we may personalize the content of these marketing communications according to your needs and interests based on other information we receive and store from you, such as your account information, order history, or other information revealed by you (including, for instance, data from your usage of our MyMedela Breastfeeding App or from your participation in surveys). We will also use information about your website usage to provide you with personalized communications which reflect your specific interests and preferences.
By consenting to marketing communications on our Website, you further consent that your receipt of communications from Medela, such as email-opens and email-clicks, may be tracked by Medela using an analytics tool provided by our third party service providers. This tool also collects information about email-forwarding, undeliverable emails and unsubscribes.
Our service providers will process your information as our data processor only on our behalf and in accordance with our instructions to help us evaluate the usage of our Website and email communications, to personalize the communications to you, to compile reports on activity and to provide other statistical and analytical services relating to the usage of our Website and email communications.
While these service providers may be located in a country which may not provide for the same level of data protection as considered adequate in the United States of America (USA), we have taken the necessary measures to ensure your personal data is appropriately protected if being transferred outside of the USA.
You can unsubscribe from our Website at any time, and withdraw your consent with effect for the future, by clicking the "unsubscribe" link at the bottom of the newsletter emails you received or on our Website within the account profile.
2.1 Essential Cookies
Cookies are small text files that our Website asks to place on your computer or other internet enabled devices, such as tablets or smartphones. If your browser is set to accept cookies, then your browser adds the text in a small file.
Except as indicated otherwise in this Policy, the cookies used by us are essential for the functioning and performance of our Website, such as by making our website work more efficiently and facilitating your use of the functionalities and services. We will not use the information stored in essential cookies for any other purpose than as strictly necessary to provide you with the services and functionalities requested.
2.2 COOKIES Consent and Personalized Tracking
By accessing our Website, you agree to us placing additional cookies on your device ("Cookie Consent") and consent to cross device tracking. These cookies will not be strictly necessary for the functioning and performance of our Website but will help us to collect some of your personal data relating to your website usage behavior in order to improve our website offering and services and/or to provide you with more personalized information and services, including targeted offers (see below Sections 2.4 and 2.5 for the corresponding cookies placed for website analysis and remarketing purposes). In case you have registered for our Website or otherwise given your consent (see Section 1.2 above), we will use such website usage information also to provide you with more personalized communications reflecting your specific interests and preferences. By accessing our Website, you further agree with the placement of cookies for enabling the services of third party marketing providers.
Your continued use of our Website will signify your consent to the described practices.
The wording of the cookie banner declaration can be viewed at the bottom of this Policy. We explain the categories of non-essential cookies that may be placed on your device and their respective purposes in the context of the different services further below (see Sections 2.4, 2.5 and 3). At all times, you have the right to withdraw your Cookie Consent and individually opt-out from the placement of cookies and any collection of your information for the different purposes at any time with effect for the future, as further explained in the respective Sections 2.3, 2.4, 2.5 and 3 below.
2.3 Managing your cookie settings
If you choose not to accept cookies, this may impair the usability of the Website and you may not be able to take advantage of some of our features and services offered.
If you use different devices to access our Website (e.g., smartphone, tablet, computer, etc.) you will need to ensure that each browser on each device is adjusted to reflect your cookie preferences.
2.4 Use of Google Universal Analytics
Google will use this information as our commissioned data processor to help us evaluate the use of our Website, to compile reports on website activity and to provide other statistical and analytical services relating to usage of our Website. We use the Google anonymization function to change the last digits of your IP address. However, if you are logged in e.g. with a Google account, Google will be able to revoke the anonymization. In any event, Medela will never receive this information and cannot revoke the anonymization.
You may prevent the collection of data generated by the cookie about your use of this Website (including your IP address) and opt-out of being tracked by Google Analytics across all websites by downloading and installing a browser-plugin which is available here.
As an alternative to installing the browser-plugin, or in case you use our Website with browsers on mobile devices, you can also opt-out of being tracked by Google Analytics if you click on the following opt-out link: Click here to opt-out of Google Analytics
In this case, an opt-out cookie will be placed on your browser that prevents any further tracking of your use of this Website by Google Analytics. Please remember that you will have to opt-out again if you delete all cookies stored on your device.
You will also have to opt-out for each device you use to visit our Website.
For an overview of privacy at Google, please click here.
2.5 Use of Google Universal Analytics
Depending on the pages you visit on our Website, we may further use certain Google Analytics Display Advertising features, such as demographics & interest reporting and remarketing features.
To enable these features, a third party DoubleClick Cookie will be placed on your device by Google (when you visit certain pages of our Website or websites from other publishers that have implemented advertising features based on the DoubleClick Cookie).
The DoubleClick Cookie stores information about your use of our Website (and eventually other websites visited in the Google advertising network), including the sites visited, ad views, page views, user interaction data, browser information, IP-address, a cookie ID, and your search history. Google will not link your name or other personally identifiable information to your DoubleClick cookie without your prior consent.
We use Google Analytics to analyze the data stored in the DoubleClick Cookie in order to obtain statistical reports on our user's demographics (age, gender) and interests. These reports help us to better understand our users and to improve our Website and services.
In addition, we use Google Analytics' remarketing features to run advertising campaigns (including Google AdWords) to users of our Website. Based on their prior visits to our Website (and their interests expressed during those previous sessions), these users will be delivered relevant targeted advertising when they browse other sites in the Internet within the Google Display Network. We may also use the Google Analytics Advertising features to help us measure the effectiveness of advertising campaigns.
Please further note that the DoubleClick Cookie also enables Google and other third party vendors to serve targeted advertising (based on your prior visits to our Website and/or other sites on the Internet). These ads may be shown on websites of Google and/or other publishers participating in the Google advertising network.
You can manage your preferences and opt-out of Google's interest-based ads in your Google Ads Settings. In this case, the unique cookie ID of the DoubleClick-Cookie is overwritten and can't be associated with a particular browser. Please note that a new DoubleClick-Cookie might be placed if you delete all cookies from your device and you may have to renew your opt-out settings.
If you would like to permanently deactivate the DoubleClick-Cookie please download and install the browser-plugin which is available here.
For an overview of privacy at Google, please click here.
2.6 Other Third-Party Cookies
Some content or applications, including advertisements, on the Website may be served by unaffiliated third parties. These third parties may place cookies on your device for their own purposes. We do not control these third parties' tracking technologies or how they may be used.
You may prevent the placement of and tracking by such third-party cookies by adjusting or modifying your browser settings accordingly. For further information please refer to your browser instructions.
2.7 AddToAny Social Plugin
This Website uses a social plugin of the service AddToAny ("AddToAny Plugin"), operated by AddToAny LLC, 717 Market Street, San Francisco, CA 94103, USA ("AddToAny"). The service of AddToAny allows users to share content on our Website more easily through social networks, such as facebook.com, twitter.com, LinkedIn.com and pinterest.com ("Social Networks").
If you access a webpage from our Website which contains the AddToAny Plugin your browser may build up a direct connection with the servers of AddToAny and download the AddToAny Plugin and its content to your browser to integrate it into the webpage you are visiting. The AddToAny Plugin will place cookies on your device and provide AddToAny with the information that you have accessed the respective webpage from our Website. Further information may be collected when you choose to interact with the AddToAny Plugin, such as by clicking on the AddToAny icon and/or sharing content with the sharing icons. The information collected by AddToAny includes server log information and browser information.
2.8 Facebook Social Plugin
This Website may use social plugins ("plugins") of the social network facebook.com, which is operated by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). The plugins are marked with a Facebook logo or the addition "Facebook Social Plugin".
When you visit a website on this Website that contains such a plugin, your browser establishes a direct connection to the Facebook servers. The content of the plugin is transmitted directly from Facebook to your browser and integrated into the website.
By integrating the plugins, Facebook receives the information that you have called up the corresponding page of our Website. If you are logged in to Facebook, Facebook can assign your visit to your Facebook account. If you interact with the plugins, for example by clicking the "I like" button or making a comment, the corresponding information is transmitted directly from your browser to Facebook and stored there.
The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your rights and setting options for the protection of your privacy can be found in the Facebook data protection information.
If you do not want Facebook to collect data about you via our Website, you must log out of Facebook before visiting our Website.
6. SURVEYS AND CONTESTS
Medela may conduct surveys and contests on this Website. Unless indicated otherwise, Medela will collect, process and use your personal data revealed by you for purposes of participating in these surveys or contests only as necessary to carry out the respective survey or contest and to provide you with personalized marketing communications. We will inform you prior to your participation about what information we will collect and how we intend to use the information collected.
Our survey and contest forms are often generated by using third party service providers. We have appropriate agreements in place to make sure that our service providers will collect and process your information only on our behalf and in accordance with our instructions.
7. CREATING ONE SINGLE RECORD WITH INFORMATION FROM OTHER SOURCES
In case you decide to use other services offered by us, such as by using our MyMedela Breastfeeding App or by using any of our websites (as available under www.medela.us, www.medela.com, www.medela.de, www.medela.ch, www.medelabreastfeedingus.com and/or other Medela websites (each including any subpages)), we may create one single record for you which combines the data we receive from you through your use of these other services with the data we receive from you through your use of the Website.
This single record helps us to better understand your needs and preferences in order to more efficiently provide you with the requested products and services, including enabling you to benefit from a more personalized experience.
We will not use such data for providing you with direct marketing communications, except where you have given your express prior consent (such as in the course of your Website or App registration). Other than as indicated in this Policy, we will not use the information for any other purposes or share the information with third parties, except where expressly permitted by you or required by applicable law.
8. DISCLOSURE OF YOUR PERSONAL DATA
8.1 Medela is operating the Website as data controller. However, to ensure the customer relationship with you is handled efficiently, and to provide you with a good customer experience, your customer relationship will be managed on local level also by the Local Group Company. The Local Group Company will be responsible for the related collection, processing and use of your personal data also as data controller. For instance, Medela may share your personal data with the Local Group Company where this is necessary to answer specific requests or inquiries submitted by you through our Website, to provide you with the services requested, or where otherwise necessary to handle the customer relationship with you. For these purposes, the Local Group Company will be granted with access to your personal data stored by Medela and will collect, store, process and use such personal data on local level for the above purposes.
8.2 In addition, Medela and/or the Local Group Company may use external service providers which are authorized to provide services on its behalf and in accordance with its instructions. These entities may have access to your personal data but only to the extent necessary to enable your use of our Website, provide related goods or services, handle your requests or inquiries or provide marketing communications as described in this Policy. For instance, Medela (and/or, as applicable, the Local Group Company) may use service providers to host our Website, store your personal data, send you marketing communications or analyze the information collected as explained in Section 2. These service providers may not disclose your personal data to any unauthorized third parties or use your personal data for any purposes other than as instructed. For further information about our service providers, please contact us as further explained in Section 11 below.
8.3 Other than as indicated above, we will not provide your personal data to any third party without your prior consent, unless we are compelled by law to do so.
9. STORAGE OF YOUR PERSONAL DATA AND DATA SECURITY
Your data will be stored on servers in Switzerland and the USA. In addition, Medela and/or, as applicable, the Local Group Company may use cloud service providers located in countries outside Switzerland, the EU/EEA, and the USA to host and process your personal data for storage, communication and marketing purposes. While the laws of those countries may not provide for the same level of data protection as considered adequate in Switzerland or the EU/EEA, we have taken the necessary measures to ensure your personal data will be handled and protected appropriately and only be processed on our behalf and in accordance with our instructions.
We will treat your personal data confidential. We have implemented appropriate technical and organizational security measures to protect your personal data against unauthorized disclosure or access, alteration, misuse, accidental or unlawful destruction or loss.
10. California Residents
Medela’s Privacy Notice for California Residents supplements the information contained in this Policy and applies solely to visitors, users, and others who reside in the State of California.
11. YOUR RIGHTS / HOW TO CONTACT US
You may have rights pursuant to your local data protection and privacy laws to request that we disclose to you all personal information that we have about you, request the correction, deletion and/or blocking of your personal information, object to the processing of your personal information for legitimate reasons, or request an electronic copy of your personal data for purposes of transmitting it to another company (data portability).
You may further at any time, with effect for the future, withdraw any consent you have given. For this purpose, please make use of the opt-out mechanisms provided for the different services (please see the respective descriptions in the corresponding Sections of this Policy) or, with respect to your Website registration, you can change your opt in status by logging into your profile on our Website.
In case of any questions about the collection, processing and/or use of your personal information or to exercise your rights please send us an email at firstname.lastname@example.org.
Notice to Nevada Residents: Without limiting the foregoing, Nevada law may allow you to specifically direct us not to sell your covered information to third parties. If you are a Nevada resident, you may submit such opt-out requests by email at email@example.com. To be effective, your request must include your full name, address and email address so that we may attempt to verify the authenticity of your request.
We reserve the right to make changes to this Policy at any time. The then current version of this Policy will be made available on the Website. While we do not intend to make changes to this policy very often, it is always a good idea to double check our most current policy statement when you visit us to be sure that you have read and agree with what information we collect, how we use it and under what circumstances we disclose it.