Effective Date: March 25, 2009

California Residents: Click here for Your California Privacy Rights

Thank you for visiting NestleInfantNutrition.com and for your interest in the Start Healthy, Stay Healthy Resource Center for Medical Professionals. The NestleInfantNutrition.com Website (also, “our Website” or “our Site”) and the Start Healthy, Stay Healthy Resource Center for Medical Professionals (also, “SHSH Resource Center for Medical Professionals”) are owned and operated by Gerber Products Company d/b/a/ Nestlé Infant Nutrition (collectively, “Nestle Infant Nutrition,” “we,” or “our”). The following is a description of the kinds of information Nestle Infant Nutrition may collect online through the NestleInfantNutrition.com Website or in connection with the SHSH Resource Center for Medical Professionals, how we use and share that information, the steps we take to protect it, and the choices you may have to control the use or disclosure of your information (collectively, “Privacy Policy” or “Policy”).

We encourage you to read this Privacy Policy before you provide Nestle Infant Nutrition any of your personal information. If you have any questions or concerns regarding this Privacy Policy, please contact us by clicking here or by calling 1-800-628-BABY (2229).

1. What does this Privacy Policy apply to?

Subject to the exceptions listed below, this Privacy Policy applies to any information collected from you online through NestleInfantNutrition.com or in connection with the SHSH Resource Center for Medical Professionals. In addition, any Nestle Infant Nutrition-owned and/or controlled domains or URLs that point to NestleInfantNutrition.com or a subpage under NestleInfantNutrition.com are also subject to this Policy.

This Policy does not generally apply to information collected from you by Nestle Infant Nutrition offline, unless we either: (i) combine such information with data collected from you online; or, (ii) specifically reference this Policy on the relevant offline form or at the time your information is collected offline.

In addition, this Privacy Policy does not apply to any of the following sites (even if we link to such sites from our Website):

1. Gerber.com, StartHealthyStayHealthy.com, or any other Nestle Infant Nutrition-owned and/or controlled domains or URLs that point to Gerber.com or a subpage under Gerber.com.
2. Sites operated by Nestle Infant Nutrition’s international affiliates
3. Sites operated by other subsidiaries of Nestlé S.A. (e.g., Nestlé USA);
4. Sites operated by independent retailers that sell Nestle Infant Nutrition products;
5. Sites operated by third party licensees of Nestle Infant Nutrition;
6. Any other site not operated and/or controlled by Nestle Infant Nutrition, even if such site is accessible from our Site or links back to our Site.

The sites listed above may maintain and post their own privacy policies. We encourage you to read the privacy policy of any other site you visit before you submit any personal information to that site. Nestle Infant Nutrition is not responsible, and disclaims any and all liability, for the independent practices or content of any third party site.

Special Note to Non-U.S. Visitors

The NestleInfantNutrition.com Website and SHSH Resource Center for Medical Professionals are intended for residents of the United States only, and we may take certain measures (such as IP Address blocking) to limit access to these resources by only such users. For this reason, this Privacy Policy is only intended to meet the laws and requirements of the United States, which may not necessarily be consistent with the laws and regulations of your home country. Any information you provide us through NestleInfantNutrition.com or for purposes of the SHSH Resource Center for Medical Professionals will be treated in accordance with this Privacy Policy.

Your Acceptance / Changes to this Privacy Policy

By using the NestleInfantNutrition.com Website and/or registering on the Website, you agree to accept the practices described in this Privacy Policy. If you do not agree with these practices, please do not use these services. We reserve the right to make changes to this Policy at any time. If we do make changes, the changes will be posted on this page and we will indicate at the top of this Policy when the changes went into effect. If we want to materially change how we use your previously collected personal information, we will notify you by email or other forms of communication (e.g., postal mail, phone), and may give you a choice to consent to or opt-out from the desired changes. Your inaction or continued use of or receipt of benefits from the NestleInfantNutrition.com Website or SHSH Resource Center for Medical Professionals after any such notices, or your explicit consent to any changes for which we require your prior approval, will signify your agreement with these changes. We encourage you to come back to our Site and review this Privacy Policy frequently so that you are constantly aware of our most current privacy practices.

2. What types of information do we ask you to provide?

To simply browse our Website or learn more about Nestle Infant Nutrition products, we do not ask you to provide any information. However, if you wish to participate in many of the services our Site and the SHSH Resource Center for Medical Professionals have to offer, or order infant formula samples, we may ask you to provide certain personal and/or demographic information, as well as establish certain login information. Personal information (as used in this Policy) refers to any information that can be used to personally identify you or contact you online or offline. This may include, for example, your name, professional designation, practice/hospital name, postal address, email address, and phone number. Demographic information (as used in this Policy) includes any non-identifiable information about you and your patients, such as your gender, professional credentials, and other related information. Login information (as used in this Policy) refers to information you create or set up when registering for an account through our Site (such as a unique username, password, and/or security question and answer). Login information allows you to access and update your online account information and preferences through NestleInfantNutrition.com.

Personal, demographic, and/or login information is only collected from you with your knowledge (i.e., if you voluntarily provide it to us) and, usually, in connection with the following activities:

• Signing up yourself for the SHSH Resource Center for Medical Professionals (“general account”);
• Signing up yourself for ordering samples through NestleInfantNutrition.com
• Entering into a sweepstakes, contest, or other promotion;
• Participating in a survey or poll;
• Contacting us with feedback, questions, or comments (such as through one of our Contact forms); or,
• Registering for or using any other service on NestleInfantNutrition.com or in connection with the SHSH Resource Center for Medical Professionals that requires the submission of personal information.

The specific types and amount of information collected for each of the items listed above will vary greatly depending on the specific feature or service you are requesting. For example, some features may require that you first create a general account by registering for the SHSH Resource Center for Medical Professionals on NestleInfantNutrition.com, while others may simply require that you provide a limited amount of personal, demographic, and/or login information, without having to register for a general account. If you choose not to provide any information when requested, you may be limited in the features and services you can enjoy.

Please note that if demographic or login information is collected for an activity that also requires personal information, we may combine and store your demographic and login information together with your personal information. We may also enhance and update the information we’ve collected about you with information we acquire from you through other means and/or from third party sources. Combining your data in this manner allows us to personalize your experience on our Website, customize the materials we send you and display on our Site based on your interests and preferences, and otherwise improve Nestle Infant Nutrition products and services to better meet your needs. For more on how we use your information, please refer to Section 3 below.

3. How do we use the information you give us?

Generally, all information collected from you is used and stored for the purposes for which the information was originally provided or as otherwise stated at the point of collection or in this Privacy Policy. For example, if you register for the SHSH Resource Center for Medical Professionals on NestleInfantNutrition.com, the information you provide us is used to deliver you the benefits and privileges that come with being a registered member of that program. This may include, for example, receiving infant formula samples, valuable information, and promotions (via email and/or postal mail) from Nestle Infant Nutrition, our affiliate brands and companies, and/or carefully selected third party partners (see Section 5 below for more information about third party partners).

Under certain circumstances, the information you give us may be handled in a manner slightly different than what is described above. Listed below are some examples of when this may occur and a brief description for each:

• Contact Forms – If you contact us through one of our online contact forms (e.g., Contact Us), your information is used to respond to your specific questions or requests. The information you provide through one of our Contact forms will not be used for any other purpose, unless you specifically authorize us to do so.
• Contests and Sweepstakes – To enter a Nestle Infant Nutrition contest or sweepstakes, you may be required to first register for a general account. In addition to using your information for the purposes set forth above, your entry information (including your personal information) may be used to notify you if you are a winner, verify your eligibility, and/or deliver you a prize. If you are selected a winner, and only with your permission, we may post on our Website limited information about you (such as your name or part of your name and city and state of residence). We may also request additional information from you (such as a photograph) that can be posted together with your name and location. Please see Section 5 below for information about contests and sweepstakes that may involve third party companies.

Third Party Offers and Information from Nestle Infant Nutrition

From time to time, we are approached by reputable third party companies and organizations that provide products or services that we believe may be of interest to you. To extend these products or services to you, we may use your personal information to mail or email you materials on their behalf. This particular service is provided to you as part of your agreement to receive communications and promotions from Nestle Infant Nutrition. As a result, these third party materials may be delivered to you together with some of our own materials. Please remember that the materials we send you in connection with this particular service come directly from Nestle Infant Nutrition and, therefore, do not require us to share your personal information with third party companies. If you would prefer not to receive these third party materials from Nestle Infant Nutrition, you must request to opt-out from receiving communications from Nestle Infant Nutrition or the SHSH Resource Center for Medical Professionals.

4. Do we use cookies or other automated technologies to collect information?

Like many other sites on the Internet, our Website may use a variety of standard web technologies to automatically collect certain information about your visit to our Site and, in return, provide you a more pleasant, convenient, and personalized experience during future visits to our Site. Examples of the types of technologies we use and how we use them are provided below.

Cookies

“Cookies" are small text files or record-keeping devices that websites often store on a user's computer, and that generally come in two forms: session cookies and persistent cookies. We may use both session and persistent cookies on our Site. A session cookie (which expires at the end of your visit) may be used to gather basic information about your visit to our Site, such as the date and time of your visit, the length of your visit, and the pages/images you viewed during your visit. This information allows us to assess (in aggregate form) how our Site is being used and, in turn, improve its contents and functionality. A persistent cookie (which remains on your computer for a longer period of time) may be used to remember the content you previously viewed on our Site and/or certain personal information you provided when registering during an earlier visit to our Site (e.g., your name, email address, practice/hospital name, etc.). This allows us to (among other things) personally greet you by your name when you come back to our Site and to display content and information that is tailored to you. In addition, a session cookie will save you the time of having to re-register or re-enter information every time you come back to our Site or try to login to access member-only areas. We do not use cookies to collect personal information; however, as explained above, we may use cookies to store – in encrypted form – certain personal information you provided during an earlier visit to our Site.

You can always disable cookies or set your browser to alert you when cookies are being sent to your computer; however, if you do so, you may not be able to register online for the SHSH Resource Center for Medical Professionals or use other features on our Site.

Log Files

We may also collect and store information in the form of web logs – i.e., files that record general activity on our Website and gather non-identifiable statistics about your browsing patterns on our Site. The information we collect and store in log files may include (among other things): (i) the type of browser and operating system you use; (ii) your computer’s IP Address; and, (iii) other information about your online visit (e.g., URL you came from to get to our Site, date and time of your visit, and which pages you viewed and for how long). Some of this information may be captured by log files in conjunction with the use of cookies. In addition to using log file information to better understand how our Site is used and to improve its functionality, we may use certain log file information (such as your computer’s IP address) together with personal information (if necessary) to troubleshoot technical problems, help ensure the security of our Website, or prohibit or restrict certain users from accessing our Site or certain features on our Site.

Web Beacons

We may also use web beacons (or clear GIFs) on our Website or include them in an email message we send you. Web beacons (also known as “web bugs”) are small strings of code that provide a method of delivering a graphic image on a web page or in an email message for the purpose of transferring data back to us. The information collected via web beacons may include some of the information described in the Log Files section above, as well as information about how a user responds to an email campaign from Nestle Infant Nutrition (e.g., the time the email is opened, where does the user link to from the email, etc.). We use web beacon information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, advertising and email auditing and reporting, and personalization.

5. Do we share your personal information?

Nestle Infant Nutrition may share the information you provide us, including your personal and/or demographic information, in the following situations:

Agents and Contractors

We may use outside companies, agents, or contractors (“vendors”) to provide support for the internal operations of our Website and to assist us with administering the NestleInfantNutrition.com programs or services. In the course of doing so, these vendors may be allowed to collect information (including personal information) from you or to process your information on our behalf. These vendors are only given access to the information they need in order to perform the specific tasks they’ve been hired to do, and are prohibited from using your personal information for any other purpose.

California Residents: Your California Privacy Rights

If you are a California resident, you may have the right to request and receive certain information about our disclosure of your personal information to third parties for their direct marketing purposes, and your choices with respect to such disclosures. However, because it is our policy not to share your personal information with third parties unless you are first given the opportunity to opt-out from such sharing, we are exempt from having to meet this requirement. If you still wish to learn more about your California privacy rights, please contact us using the contact information provided at the top of this Policy.

Legal and Business Transfers

We may disclose your personal information if we are required to do so by law, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, respond to any claims, or protect the safety or rights of Nestle Infant Nutrition, our consumers and customers, or the public.

In the event of a merger or acquisition of all or part of Nestle Infant Nutrition or our parent company by another company, or in the event Nestle Infant Nutrition or our parent company were to sell or dispose of all or a part of the Nestle Infant Nutrition business, the acquirer may have access to the information previously maintained by Nestle Infant Nutrition, which could include your personal information. Similarly, any information in our possession, including your personal information, may be transferred to a third party entity as part of a corporate reorganization, insolvency proceeding, or other similar event.

Aggregate Information

From time to time, we may share your demographic information in anonymous and aggregate form with third party companies for the purpose of assessing overall trends about our consumers and conducting demographic and research studies. This information does not contain any of your personal information and is only shared in a bundled format. The information shared for these purposes may include non-identifiable information captured through the use of cookies or other similar web technologies, as described in Section 4 above.

6. What measures do we take to protect your personal information?

Nestle Infant Nutrition takes a variety of measures to protect the confidentiality and security of your personal information. These measures include, but are not necessarily limited to, the following:

• We store your personal information in secure operating environments that are not available to the public (e.g., behind industry standard firewalls);
• With respect to Nestle Infant Nutrition employees and vendors, your personal information is only accessible to authorized individuals on a strict need-to-know basis only;
• We verify the identity of all registered users before they can access the personal information we maintain about them; and,
• We do not collect financial information such as credit card numbers through our Website.

7. How can you opt-out from Nestle Infant Nutrition communications or access and update your information?

The following outlines the choices you may have with respect to opting-out from Nestle Infant Nutrition communications, or accessing and updating the information we’ve stored about you:

You always have the option not to give us any of your personal information. However, if you choose this option, you will be limited in the services and programs we can provide you, as already mentioned above.

If you want to update your information, please visit the "Update profile" section on our Website and update your information. Please note that it may take up to 30 days for your request to become effective.

Along with every communication, newsletter, or booklet that Nestle Infant Nutrition sends you, we provide you a mechanism to discontinue receiving future communications (i.e., unsubscribe). Simply follow the unsubscribe process or directions provided in the relevant email or booklet. Please see Section 7b above for important information about residual communications.

If the mechanism set forth above is not available to you or you wish to make a different request, please contact us using the information provided at the top of this Policy.

Please note that regardless of your opt-out selections, we reserve the right to continue sending you administrative or operational communications, such as important email confirmations (e.g., in response to an online registration or offline order) or to inform you about important product announcements (e.g., recalls) or updates to our Site (e.g., updates to our legal terms or privacy policy, site maintenance, etc.).

8. Do we collect information from children under 13?

Nestle Infant Nutrition does not knowingly solicit or collect personal or other information from children under the age of 13 through Nestleinfantnutrition.com or the SHSH Resource Center for Medical Professionals. Our Site and the SHSH Resource Center for Medical Professionals are intended for Medical Professionals. If we learn at any time that we have inadvertently collected personal information from a child, we will promptly delete the information from our records.