GERBER PRODUCTS COMPANY WEBSITE PRIVACY POLICY

This Policy is a statement of our general privacy policy and practices governing the ways in which we collect, hold and use information about individual persons. Our privacy policy is easy to find as it is located on our homepage and each page of this website. Where personal data is requested, further explanation may be provided where appropriate, as to the purposes for which the data will be used. This Policy, coupled with any supplementary explanation, is designed to provide privacy protection tailored to the individual visitor to, or user of, this website.

1. Pledge on Privacy

The term "personal data" as used in this Policy refers to information such as your name, birth date, e-mail address or mailing address, which can be used to identify you. Gerber Products Company ("Gerber") will not process your personal data without your consent. In so doing, we ensure compliance by our staff with strict standards of security and confidentiality.

The next sections explain how and when we collect personal data from you.

2. Intended Use of Personal Data

Most of our services may require registration. When you register with us, you may need to complete certain fields in order for us to send you information via postal mail or email. In these situations, if you chose to withhold any personal data requested by us, it may not be possible for you to gain access to certain parts of the site and for us to respond to your query.

We also request information on you and your child in order to provide you the most relevant and timely information on your child's development progress (phase, stage or growth), deliver you to the proper site specific location, send relevant email and for promotional opportunities.

GERBER processes personal data for specific and limited purposes, which we inform you about when we ask you for information. For example, we may collect and use personal data to provide you with products or services, to bill you for products and services you request, to market products and services which we think may be of interest to you, or to communicate with you for other purposes. GERBER keeps your data only for as long as is reasonably needed for such purposes and in accordance with any applicable legal or ethical reporting or documentation retention requirements.

For users who submit information (email addresses) of their friends to our site, GERBER will not store this information or market to these individuals, unless the recipient of the email personally opts-in to the GERBER program by registering on the site.

3. Non-Disclosure of Information

Personal data may be transferred to third parties that act for or on behalf of GERBER, or in connection with the business of GERBER, for further processing in accordance with the purpose(s) for which the data was originally collected. GERBER will not sell, share or otherwise distribute your personal data to third parties outside the GERBER or Novartis Group of Companies, if you choose to opt-out of our partnership program. Where disclosure of personal data to a third party occurs we will endeavor to ensure that the processing is performed in accordance with the purposes and within the limits under which the data was originally collected. Such third parties may operate under different privacy policies. In the event that this website is closed down, all personal data will be destroyed or you will be notified of any new manner of use of the data so you may revoke your consent of the use of this data.

4. Right of Access

You have the right to access and update your personal data or to require their deletion. We endeavor to ensure that personal data is up-to-date, accurate, and complete. If you wish to access or correct your personal data held by us, please call 1-800-4-GERBER. You may also update your information by accessing the Account Update section of our website. Your requests will be dealt with in a prompt and proper manner. No charge will be levied for complying with a correction request. Requests to delete personal data will be subject to any applicable legal and ethical reporting or document filing or retention obligations imposed on GERBER.

5. Security and Confidentiality

To ensure the security and confidentiality of personal data that GERBER collects online, GERBER uses data networks protected by industry standard firewall and password protection. Access to personal data is restricted to those employees and approved agencies working on behalf of GERBER or NOVARTIS, who have a need to use the data and who have been trained to handle such data properly and observe strict standards of confidentiality. If an employee breaches our policies and procedures he/she will be disciplined accordingly. Staff compliance with our policies and procedures is regularly audited and reviewed. While we cannot guarantee against any loss, misuse or alteration to data, we try to prevent such unfortunate occurrences.

6. Data Transfer Abroad

We may transfer your data to one of GERBER's databases outside your country of domicile. If the level of privacy protection in a country does not afford an adequate level of privacy protection, we will ensure that data transfers to GERBER databases in that country are adequately protected and that the transfer of data to third parties in such countries will not occur unless we obtain your express consent to such transfer in advance.

7. Anonymous Data and "Cookies"

If you are a non-registered user, much of the information that GERBER collects from its website is anonymous information, such as the pages you visit and searches you perform. When you visit our website we do not collect any personal data from you unless otherwise authorized by you. Anonymous information is processed by GERBER to help improve the contents of the site and to compile aggregate statistics about individuals using our site for internal, market research purposes (for example, to determine how many times or if a particular page in the site is being used). In so doing, GERBER may install "cookies" that collect the first level domain name of the user (e.g., "bigmail.com" from and e-mail address of john@bigmail.com) and that date and time of the access. This anonymous form of tracking expires at the end of a session, when you leave our website.

If you are a registered user, the site will rely on a persistent "cookie" to enable a personalized site experience and user tracking. Your name and your child's name are captured in order to personalize the site to you.

"Cookies" by themselves cannot be used to discover the identity of the user. A "cookie" is a small piece of information that is sent to your browser and stored on your computer's hard drive. "Cookies" do not damage your computer. You can set your browser to notify you when you receive a "cookie," and this will enable you to decide if you want to accept it or not.

8. Spamming

GERBER does not condone "spamming". Spamming is defined as sending unsolicited e-mails, usually of a commercial nature, in large numbers and repeatedly to individuals with whom the sender has had no previous contact or who have declined to receive such communications.

GERBER allows you to opt-in to our email program during the registration process and will provide clear opt-out choices on every email sent from GERBER. Once you have opted-in to GERBER emails, where GERBER believes that certain product, health, or other information is of importance to you it reserves the right to inform you by e-mail whilst giving you the choice of opting out of such service.

9. Personal Information and Children

GERBER will not knowingly collect, use or disclose personal data from a minor under the age of 13 without obtaining prior consent from a person with parental responsibility (e.g., a parent or guardian) through direct off-line contact. We will provide the parent with (a) notice of the specific types of personal data being collected from the minor, and (b) the opportunity to object to any further collection, use, or storage of such information. GERBER abides by laws designed to protect children.

Parent age data is collected to comply with COPPA regulations. The GERBER site is not intended for audiences under 13 years of age.

Users may choose to add their child's name and/or picture onto the website to enhance your personal site experience. Your child's name and/or photo will not be sold to or shared with third parties or tracked and monitored by GERBER.

10. Links to Other Sites

This Privacy Policy applies only to this website to the exclusion of third party websites. GERBER may provide links to other web sites that we believe may be of interest to our visitors. You will be notified via a transition page that you are leaving the GERBER site. We aim to ensure that such websites are of the highest standard. However, due to the nature of the World Wide Web, GERBER cannot guarantee the standards of every website link it provides nor shall GERBER be held responsible for the contents of non-GERBER sites.

11. Contact GERBER

If you have any queries or complaints about our compliance with this Privacy Policy, or if you would like to make any recommendations or comments to improve the quality of our Privacy Policy, please contact us. You can also call us at 1-800-4GERBER. This privacy policy is effective as of March 31, 2003. We aim to constantly improve the tools available to you to manage the data that you provide to us. Please refer to this page from time to time to review these other new features.