This Privacy Statement was last updated October 2023.

Welcome to FIT4diabetes.com (the “Site”). On behalf of the Forum for Injection Technique (“FIT”) this Site is operated by Embecta Corp., a United States corporation (herein “Embecta” or “we” or “us”).

The Site has been created for people with diabetes, their careers and Healthcare Professionals to serve as a comprehensive source for education and data on optimal injection technique for people with diabetes mellitus (collectively, the “FIT4diabetes.com facilities”). Embecta is partnering with and is a sponsor of FIT, whose mission is to support people with diabetes using injectable therapies, through evidence based practice in order to achieve the best possible health outcomes that are influenced by correct injection technique, thus ensuring that the dose is delivered to the right injection site, using the right technique, every time.

You are important to us and, as described in this Privacy Statement, we will take appropriate measures intended to protect your privacy as you use this Site. This Privacy Statement sets forth Embecta’s approach with respect to information that is collected from users of this Site. This Site is directed at Canada and only intended for use in Canada.

Acknowledgement of Our Privacy Statement

FIT4diabetes.com is operated by Embecta on behalf of the FIT board Canada. FIT4diabetes.com is an informational Site that serves as a comprehensive source for education and data on injection technique practices for the care of diabetes. By using FIT4diabetes.com, you acknowledge that you have reviewed the terms of our Privacy Statement (the “Privacy Statement”) and agree that we may process, collect, use, disclosure and transfer your Personal Data in accordance therewith.

If you do not agree with these terms, you may choose not to use our Site, and please do not provide any Personal Data through this Site. This Privacy Statement forms part of our Site Terms of Use and such shall be governed by and construed in accordance with the laws of Canada. Please note that this Privacy Statement does not apply to the providing or use of Personal Data other than through the Site, nor to the providing or use of Personal Data of past or present employees of, or consultants engaged by, Embecta and/or its subsidiaries, for employment or benefits administration purposes, both of which are governed by Embecta Policies designed for those respective purposes (the “Other Policies”)

Below is a table of contents listing the areas covered by our Privacy Statement. Please read our entire Privacy Statement carefully. Should you have any questions about this Statement or about our data processing, collection, storage and use practices, please contact us as provided below.

Definitions

“Aggregated Data” includes customer demographics, interests and behaviour based on Personal Data and other information provided to us, which has been compiled into an anonymous form.

“Personal Data” includes all information that identifies an individual, on its own or in combination with other data, including, by way of example, the individual’s name and e-mail address.

“Public Information” includes information posted to any public areas of the Site, such as bulletin boards, chat rooms and comment areas. Please refer to our Terms of Use.

“Unsolicited Information” includes any ideas for new products or modifications to existing products and other unsolicited communications. Personal Data included in Unsolicited Information will be handled in the manner set forth in this Privacy Statement and our Terms of Use.

The terms “you”, “your” and “yours” when used in this Privacy Statement means any user of this Site.

Changes to Our Privacy Statement and Consent

At times it may be necessary for Embecta to make changes to this Privacy Statement. Embecta reserves the right to update or modify this Privacy Statement at any time and from time to time without prior notice. Please review this Statement periodically. Your continued use of the Site after any changes or revisions to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.

Note About Children

If you are under the age of eighteen, please do not use this Site and do not provide us any Personal Data.

This Site is not directed at children and the facilities offered on this Site are designed for individuals who are 18 years of age or older. Should an individual whom we know to be under 18 send Personal Data to us, we will not retain such information except that, in certain instances, we will use that information to satisfy our obligations to follow up on product comments or complaints and we will respond directly to the individual to inform him or her that we do not accept Personal Data from persons under 18. In addition, although not required by the law, if you are aware that a person under 18 has provided Personal Data to us, please contact us as provided below.

What Information Do We Collect?

Information That You Provide

If you contact us through info@FIT4diabetes.com or use certain other of the personalized options it offers, we will create a profile that includes your name, mailing address, e-mail address, and other information that you provide that is pertinent to your specific situation. We may combine such information with data gathered from other sources or combine it into Aggrogated Data. For instance, if incorrect postal codes are received, we may use third party software to correct them. When you contact us, we may keep a record of that correspondence and may occasionally ask you to complete surveys for research purposes.

In some instances, we contract with outside parties to collect and maintain our information collection servers and to perform technology and related services. We provide any such service providers with only the information they need to perform their specific function, and we require them to protect your Personal Data in accordance with this Privacy Statement.

Aggregated Data

In an ongoing effort to better understand and serve our users, Embecta often conducts research on Aggregated Data. This Aggregated Data may be shared with government agencies, its affiliates, agents and business partners. This Aggregated Data does not identify you personally. Embecta also may disclose Aggregated Data in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Transfer of Your Data Abroad

By voluntarily providing us with your Personal Data, you are agreeing to our use of it in accordance with this Privacy Statement. Some Personal Information processed through this Site may be transferred across international boundaries to countries that have fewer protections for Personal Data. By visiting this web Site you consent to these transfers. If you provide Personal Data to this Site, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Embecta and the affiliates, agents and service providers referred to herein located in the United States and in other countries.

What are Your Choices?

We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal reporting or document retention requirements. We will take reasonable steps to update, correct or, upon your request, delete your Personal Data in our possession that you have previously submitted or collected. In order to request an update, with respect to your Personal Data, please contact us as provided below. If at any time you wish not to receive further communications, you may also follow the unsubscribe procedure included in our communication.

Legal Basis for Processing

We process Personal Data based on your consent, our legitimate interests, or to fulfill a contract with you or request from you. If we are processing based on consent, we will obtain consent that is clear, free, and informed. You are always able to withdraw your consent for future processing or decide not to consent when asked.

Access

Embecta permits a reasonable right of access and review of Personal Data held by Embecta by the individual to whom the Personal Data relates; however, to guard against fraudulent requests for access, Embecta will require information which it determines is sufficient to allow it to confirm the identity of the person making the request before granting access or making corrections. Embecta will endeavor to provide the information in question within a reasonable time and may charge an appropriate cost (e.g. photocopying, mail charges) to the individual making the request. Embecta will only amend your Personal Data if you successfully demonstrate the inaccuracy or incompleteness of such Personal Data.

In addition, in certain circumstances, Embecta may decline to provide access to Personal Data, including where Embecta determines any of the following:
(a) Provision of the Personal Data may result in disclosure of:
i. The Personal Data of a third party; or
ii. confidential commercial information;
(b) The Personal Data is subject to attorney-client or litigation privilege or a professional privilege or obligation;
(c) The Personal Data does not exist;
(d) The Personal Data could reasonably be expected to threaten the life or security of another individual;
(e) The Personal Data is generated in the course of formal dispute resolution process; or
(f) The Personal Data is collected pursuant to purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.


Please note that although after receiving a request to update, correct or delete information, we will make reasonable efforts to effect such a change promptly, it is not always possible to complete the process before another communication is distributed. We apologize for any inconvenience this may cause. Even if you have requested removal of your Personal Data from our lists, Embecta reserves the right to retain it in our files in some limited circumstances such as when such Personal Data may be necessary to honour your request to opt out of further communications, resolve disputes, troubleshoot problems or as provided in our Terms of Use. If Embecta is required to retain any portion of the Personal Data for such purposes, Embecta shall use reasonable efforts to limit such Personal Data to what is necessary to accomplish the particular purpose. Further, you acknowledge that due to technical constraints and the fact that we back up our systems, Personal Data may continue to reside in our systems even after deletion. Therefore, you should not expect that your Personal Data will be completely removed from our systems in response to your request.

How Do We Use Your Personal Data and Other Information?

Embecta uses the Personal Data you provide for our business purposes in a manner that is consistent with this Privacy Statement. If you provide Personal Data for a certain reason, that Personal Data will be available to us for use in connection with the reason for which it was provided or for a consistent purpose. For instance, if you contact us by e-mail, we may use the Personal Data you provide to respond to you. We may also combine Personal Data that you have provided to us with information obtained by us from other parties.

Embecta and its affiliates also may use your Personal Data and other information collected through the Site to help us improve the content and functionality of the Site, to better understand the needs of the visitors to FIT4diabetes.com.

Embecta and its affiliates may seek your consent to use this information to contact you on behalf of the FIT, electronically or otherwise, in the future to tell you about new developments in the area of diabetes care that we believe will be of interest to you. If we do so, each promotional communication we send you will contain instructions permitting you to “opt out” of receiving future communications.
If at any time you wish not to receive any future communications or to have your name deleted from our mailing lists, you may follow the “unsubscribe” procedure included with our communication. In addition, you may e-mail us at info@FIT4diabetes.com. See How to Contact Embecta below.

Do We Share the Information that We Receive?

Embecta considers your information to be a vital part of our relationship with you. Embecta will share information including Personal Data with its partners, subsidiaries, and affiliates that have also agreed to be bound by this Privacy Statement in so far as it is necessary to provide the FIT4diabetes.com facilities. In addition, Embecta, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples include mailing information, analyzing website usage, maintaining databases and processing payments. When we retain another non-affiliated company to perform a function of this nature, we seek to provide them with only the information that they need to perform their specific functions, and they protect the Personal Data in alignment with the privacy statements on their website. You can opt out of sharing Personal Data with third parties that are not obligated to our Privacy Statement by visiting the cookies link at the bottom of the Site.

There are also a limited number of circumstances in which we may share your Personal Data and other information in our possession with certain additional third parties without further notice to you, as set forth below:
Embecta may disclose your Personal Data and other information if required to do so by law or in the good faith belief that such action is:

(a) required by law;
(b) required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with rules of court relating to the production of records;
(c) made to a government institution or part of a government institution that has made a request for the information and identified its lawful authority to obtain the information; or
(d) made to a person who needs the information because of an emergency that threatens the life, health or security of an individual.

Public and Unsolicited Information

If you include Personal Data in such Public Information, we will treat such Personal Data as provided herein, but we caution you that, because such information (including your Personal Data) was made available in a forum accessible by the public, the use and disclosure of information by others accessing the Site is not monitored or controlled in any way by Embecta nor are their activities governed by this Privacy Statement.
In addition, if you submit unsolicited Personal Data we will use it as provided herein, however, the other information included in such unsolicited submission is not covered by this Privacy Statement. Please refer to our discussion of “Public and Unsolicited Information” contained in our Site Terms of Use.

Please note that, as set forth above, this Privacy Statement does not apply to the providing or use of certain Personal Data other than through the Site nor to the providing or use of Personal Data of past or present employees of, or consultants engaged by, Embecta and/or its subsidiaries, for employment or benefits administration purposes, both of which are governed by Embecta policies designed for those respective purposes.

Links to Other Websites

This Privacy Statement applies only to this Site. This Site may frame or contain references or links to other Embecta web sites as well as other web sites not operated or controlled by Embecta (the “Third Party Sites”) none of which sites are governed by the policies and procedures we describe here. The links from this Site do not imply Embecta’s review or endorsement of the Third Party Sites. We suggest that you contact those sites directly for information on their privacy, security, data collection and distribution policies.

Security

Embecta takes reasonable steps to protect any Personal Data you provide to us and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Unless otherwise stated on the relevant page of the Site, Embecta uses general security standards but has not taken additional action to secure data provided to its sites, and such transmissions are subject to normal Internet security risks. As noted, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from this Site may not be secure, and you should therefore take special care in deciding what information you send to us. Please keep this in mind when disclosing any Personal Data to Embecta or to any other party via the Internet. Moreover, when you use passwords, ID numbers, or other special access features on this Site, it is your responsibility to safeguard them, in this respect please refer to the Terms of Use.

How to Contact Us

Please also feel free to contact us if you have any questions about Embecta’s Privacy Statement or the information practices of this Site.
You may contact us as follows:

E-mail address: info@FIT4diabetes.com

Address:
Embecta Corp, 300 Kimball Dr, Suite 300, Parsippany, NJ, 07054, United States