Privacy Policy PRIVACY POLICY LITTLE-EGG.COM The purpose of this Privacy Policy is to inform you, the individual user or visitor of the Site (as defined herein) about the types of personal information Little Egg Gifts Inc. (as follows, “Little Egg,” “Company,” “we,” or “us”) collects, uses and shares when you visit, use or Subscribe (as defined within the Terms and Conditions) with www.little-egg.com (the “Site”). It explains how we collect, use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information. Definitions outlined in the Terms and Conditions of this Site, together with any documents and/or additional terms they define are expressly incorporated by reference into this Privacy Policy. We are proud to demonstrate our commitment to your privacy by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act and the Privacy Act of British Columbia, the applicable privacy laws of the European Union, including the General Data Protection Regulation, and the applicable federal privacy laws of the United States, including the Children’s Online Privacy Protection. We will treat personal information in a manner consistent with our Privacy Policy unless we have your consent to treat it differently. Article 1 – Collection of Personal Information 1.1 To which companies does this Privacy Policy apply? This Privacy Policy applies to the collection, use, and disclosure of personal information by Little Egg. 1.2 What is personal information? Personal information is any factual or subjective information about an identifiable individual. Personal information includes such information as a person’s name, address, email address, phone number, date of birth and financial information. Specific personal information, such as your name, address, phone number or email address, is obtained only if you supply it voluntarily (“Personal Information”). 1.3 What Personal Information do we collect? When you visit our Site, we automatically collect certain Personal Information, including: unique device identifiers;your IP address;your web browser;your time zone;mobile network information;the previous cookies that we installed on your device;how you interact with the Site;the individual webpages that you view;any terms you might search;referring and exiting pages; how many times you’ve visited our site;date and time stamps for your visits;transmitted data volume;language preference;operating system information. 1.4 We also collect Personal Information that you may provide to us, including: your legal name;profile photos;date of birth; your telephone number;personal messages, photos, and videos;your postal code; your email address; your address;your billing address;payment information; personal preferences or interests; PayPal Account identification; andother personal information relating to you that you may provide. 1.5 Personal Information that is identifiable to children and youth is particularly sensitive, so we recommend that parents and guardians take steps to limit and monitor their children’s Internet activities directly, or through software and other tools. When we do collect Personal Information identifiable to children and youth, it is on a limited basis and with the expectation that it is submitted to us by a Parent/Guardian or under the supervision of a Parent/Guardian. In such cases, we strictly limit the use of that personal information to the purposes for which it was collected. For example, a child or youth’s legal name is collected, used, and disclosed for the purpose of creating and sharing their page with family and friends. 1.6 To provide the contracted services, the only Personal Information that we collect from a parent or guardian about their children or youth are their Legal Names and profile pictures. By granting Family/Friends access to the pages a Parent/Guardian creates for their children or youth, the parent or guardian acknowledges and consents that Family/Friends will have access to profile photos, dates of birth, personal messages, photos, and videos, personal preferences or interests, and other personal information relating to the children or youth that Users may share to the webpages created by the parent or guardian. By sharing a Guest link, the Parent/Guardian acknowledges and consents that the shared Guest link, which only discloses the children or youth’s Legal Names and profile picture, is accessible by anyone who is, directly or indirectly, provided with the Guest link. While Little Egg cannot control sharing of the Guest link, We can control the Personal Information that is available to Guests. Thus, the only Personal Information that will be disclosed via the Guest Link to third parties is the children or youth’s Legal Name and profile picture. 1.7 Pursuant to the Children’s Online Privacy Protection, Rule 15 U.S.C 6501-6508, Little Egg provides the following direct notice to a parent or guardian who enrolls in a Parent/Guardian account: a. If a parent or guardian enrolls in a Parent/Guardian account, Little Egg has collected the parent or guardian’s online contact information and the parent or guardian has consented to the collection, use, or disclosure of the child’s personal information. Little Egg also collects the parent or guardian’s information incase Little Egg must protect the safety of the child. b. Little Egg will not disclose any personal information from the child if the parent does not provide consent. c. Little Egg has no control over Personal Information disclosed by users’ submissions through the Site to webpages created by a Parent/Guardian for their children or youth. Incidental to users’ submissions, Little Egg collects, and stores data related to: profile photos; date of birth; personal messages, photos, and videos; personal preferences or interests; and other personal information relating to the child that users may provide. If unrelated to the child’s safety, Little Egg will not disclose any of this information. d. This Privacy Policy contains all of Little Egg’s informational practices. e. A parent or guardian can provide verifiable consent to the collection, use, and disclosure of the information by using an online payment system that provides notification of each discrete transaction to the primary account holder. f. If the parent or guardian does not provide consent within a reasonable time from the date the direct notice was sent, Little Egg will delete the parent’s online contact information from its records and terminate the Parent/Guardian’s account and associated pages. g. The parent or guardian may refuse to permit the use, and require the deletion, of the information collected. The parent can do so by contacting Little Egg by email at hello@little-egg.com. h. A parent or guardian may request to review the Personal Information collected by the Company. This includes a description of the specific types or categories of personal information collected by the Company by contacting hello@little-egg.com. 1.8 When and how do we obtain consent? Before Little Egg collects, uses, or discloses your Personal Information, we first obtain your express or implied consent. The form of consent will largely depend on the sensitivity of the information and the reasonable expectation of privacy that you may have in the specific circumstance. We may obtain your express consent in writing, through electronic means, or verbally. 1.9 Express consent to collect, use, and disclose your Personal Information is obtained when you submit your name, date of birth, telephone number, postal code, and email address while registering for a Parent/Guardian Account, a Families & Friends Account, or a Guest account. In order to respond to your inquires, express consent to collect, use, and disclose your Personal Information is also obtained when you submit your Personal Information via a contact form on the Site. Additionally, when you subscribe to a Families & Friends account or Parent/Guardian account, we collect certain information from you including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone numbers. We refer to this as “Transaction Information” and only collect, use, and disclose this information, as required, to process payments, for taxation purposes, and to perform fraud and risk assessments. 1.10 Alternatively, your consent may be implied through an action that you’ve taken or by continuing to use the Site after being notified of our Privacy Policy. By accepting the Privacy Policy and continuing to use our Site, you provide implied consent for us to collect, use, and disclose, on a limited basis, subject to the terms contained herein, information about: your device; your IP address; your web browser; your time zone; the cookies that are installed on your device; how you interact with the Site; the individual webpages that you view; any terms you might search; referring and existing pages; how many times you’ve visited our site; date and time stamps for your visits; transmitted data volume; operating system information. Since we obtain consent the first time we receive your Personal Information, by continuing to make use of our services, you imply that your consent is on-going in accordance with this Privacy Policy. 1.11 How do we use technology to collect information through the Site? Like most online businesses, We collect Personal Information using the following technologies: a. Cookies We use “cookies” to assist us in customizing the Site, storing user preferences, and to conduct interest-based advertising. A “cookie” is a data file that is placed on your device and often includes an anonymous unique identifier. Cookies do not damage computer systems or files, and only the website that transferred a particular cookie to you can read, modify, or delete such cookie. We use the following cookies: Necessary cookies: Without these cookies, it would be impossible to use the Site, as they are required in order to perform basic tasks on the Site. The Necessary cookies we use are as follows: NameDuration RetainedDescriptioncookielawinfo-checkbox-advertisementSessionSet by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Advertisement” category.CookieLawInfoConsent1 yearRecords the default button state of the corresponding category & the status of the CCPA. It only works in coordination with the primary cookie. cookielawinfo-checkbox-others11 monthsSet by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Others” category.cookielawinfo-checkbox-analytics11 monthsSet by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Analytics” category.cookielawinfo-checkbox-performance11 monthsSet by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Performance” category.cookielawinfo-checkbox-functional11 monthsSet by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Functional” category.cookielawinfo-checkbox-necessary11 monthsSet by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Necessary” category.Viewed_cookie_policy11 monthsSet by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data. Other cookies: These cookies store the user’s preferences while navigating the Site. We use “other” cookies in order to store user choices like which currency they prefer. We use the following “other” cookies: NameDuration RetainedDescriptionwp_woocommerce_session_6d37a5bbc75ee3a78fb233233477b2c2 daysNo descriptionWoocommerce_multicurrency_language1 yearNo descriptionWoocommerce_multicurrency_forced_currency1 yearNo description Analytics cookies: Analytics cookies help us extract information related to the way our users use our Site, with the aim of improving our services. We use the following “analytics” cookies: NameDuration RetainedDescription CONSENT2 yearsYouTube sets this cookie via embedded youtube-videos and registers anonymous statistical data Advertising cookies: We conduct interest-based advertising, also referred to as targeted advertising or behavioral advertising. “Retargeting” means that the ads that you are being served are personalized based on your behavior when browsing online. Using Retargeting cookies also allows us to provide you with offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about. We cooperate with third party service providers placing ads (banners or links) for us on other websites. These advertising service providers may collect information about your visits to our Site and your interaction with our services, as well as your visits to other websites. Such information does not include your name, address, email address, but may contain browser-related information, such as information about searches that you have made. We use the following “advertising” cookies: NameDuration RetainedDescriptionyt-remote-connected-devicesNeverYouTube sets this cookie to store video preferences of the user using embedded YouTube videosyt-remote-device-idNeverYouTube sets this cookie to store video preferences of the user using embedded YouTube videosVISITOR_INFO1_LIVE5 Months, 27 daysYouTube sets this cookie to measure bandwidth that determines whether the user gets the new or old player interface.YSCSessionYouTube sets this cookie to track the views of the embedded videos on the YouTube pages. If you don’t want to use cookies with our Site, there is a simple procedure within your browser that will allow you to delete the existing cookies, automatically decline future cookies, or be given the option to accept or decline particular cookies in the future. Please note that declining cookies on our Site will significantly reduce or impair your user experience. As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. Generally, you can opt out of targeted advertising by visiting: a. FACEBOOK – https://www.facebook.com/settings/?tab=ads; b. GOOGLE – https://www.google.com/settings/ads/anonymous; c. BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads; d. Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. b. Log Files We use “Log Files” to track actions that occur on the site and collect data including your IP Address, internet service provider, referring and exiting pages, date and time stamps, transmitted data volume, operating system, and browser type. This data is required to ensure the security of our Site. We will process this data on the basis of our legitimate interest pursuant to Article 6 para. 1f, GDPR. c. Pixels We use Pixels which are electronic files that are used to unobtrusively record information about how you browse the Site. These are used in conjunction with our service providers for the purposes of analyzing what content you view on our Site. Article 2 – Use of Personal Information 2.1 How do we use your Personal Information? We collect your Personal Information for a variety of reasons, including: sending you information and communications; responding to inquiries and other requests; conducting contests and promotions; processing subscriptions and payments; optimizing your experience on our Site; to ensure a Parent/Guardian (as defined in the Terms and Conditions) can control which users views the pages they create for their child; providing you with invoices and registration confirmations; screen payments for potential risk or fraud; and to assess the success of our marketing and advertising campaigns. We may also use your Personal Information as otherwise permitted by law. 2.2 Where do we store your Personal Information? We store your Personal Information in our offices in Canada and our servers in Ireland. Our service providers may, from time to time, also hold your Personal Information in connection with purposes for which you provided your consent. Our service providers may store your information temporarily in the United States, Ireland, or Canada. We keep a record of your Personal Information, correspondence, or comments in a file specific to you. 2.3 How long will we use, disclose, or retain your Personal Information? Your Personal Information will be used, disclosed, or retained for as long as necessary to fulfill the purposes for which it was collected and permitted or required by law. In any case, we only disclose your Personal Information as permitted or required by law, as you consent to, or as required to fulfill a contract with you involving our third-party service providers. We make reasonable security arrangements to protect your Personal Information against risks such as unauthorized access, collection, use, disclosure or disposal. We integrate these security measures into the design, application, and operation of the Site. We take reasonable measures to evolve with the risks, so that the integrity and confidentiality of your Personal Information and our systems are maintaine 2.4 How we will communicate with you. Through our Site and various offline means, you may sign up or opt-in to receive communications from http://www.little-egg.com. If you do not opt-in, We will not send you any communications, including promotional offers. Each promotional communication sent to you by us contains an “unsubscribe” link or other unsubscribe mechanism, allowing you to opt-out at any time. Article 3 – Disclosure of Personal Information 3.1 We disclose information about you in limited circumstances to our service providers with the appropriate safeguards in place. We use service providers (including our affiliates) to help us operate our Site, and to administer business activities on our behalf, such as sending emails and communications, processing payments, embedding videos, facilitating the sending and receiving of financial gifts, customizing user preferences, conducting contests and promotions, and analyzing how visitors use our Site. We may share your respective Personal Information with these third parties for those limited purposes. All our service providers have their own privacy standards to protect the privacy of your Personal Information. By using this Site, you acknowledge that you have viewed the privacy policies and terms and conditions linked below and that you consent to the processing of data by our service providers. a. WooCommerce Plugin and WooCommerce MultiCurrency This Site uses WooCommerce Plugin and WooCommerce MultiCurrency Plugin. WooCommerce is the world’s most popular open-source e-commerce platform owned by Automattic. Automattic places cookies, as described above, on your computer to help the Site analyze how you use our Site. Like most online service providers, Automattic collects information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, mobile network information, as well as log information when you use our Site. Automattic also collects, uses, and discloses transactional information, usage information, location information, stored information, interactions with other users’ site, and other information from pixel tags. To learn more about the personal information that Automattic collects, please see: https://automattic.com/privacy/.The personal information generated by the cookies will be transmitted to and stored by Automattic on their servers in Ireland. By using this Site, you consent to the limited processing of data about you by Automattic in the manner and for the purposes set out above. b. YouTube This Site uses YouTube to embed videos. Youtube allows users to discover, watch and share videos and other content, provides a forum for people to connect, inform, and inspire others across the globe, and acts as a distribution platform for original content creators and advertisers large and small. YouTube is service provided by Google LLC (“Google”). YouTube sets cookies via the embedded YouTube videos and registers anonymous statistical data, stores the video preferences of the user using embedded YouTube videos, measures the bandwidth that determines whether the user gets the new or old player interface, and tracks the views of embedded videos on YouTube pages. To learn more about the personal information that Youtube collects, please see: Terms of Service (youtube.com) and Privacy Policy – Privacy & Terms – Google. By using this Site, you consent to the limited processing of data about you by Google in the manner and for the purposes set out above and in their Privacy Policy. c. Stripe This Site uses Stripe to charge and collect payments from users. Stripe provides software and services for businesses to accept and manage payments online. Stripe sets cookies to guarantee the proper functioning of their services, detect and prevent fraud, and to analyze and improve the Services. Stripe uses necessary cookies for authentication, fraud prevention and detection, security, and features. Stripe uses preference cookies to remember your preferences and recognize you when you use their services again. Additionally, Stripe also uses analytical cookies to understand how users interact with their services and advertising cookies to offer and measure your engagement with their advertisements. For more information regarding Stripe’s privacy policy, please see: Stripe Cookies Policy – CA. By using this Site, you consent to the limited processing of data about you by Stripe in the manner and for the purposes set out in their privacy policy. d. PayPal This Site uses PayPal to facilitate the sending and receiving of financial gifts between users and the Parent/Guardian. When you create an account or use PayPal’s service, PayPal may collect: your First and last name; Address; Phone number; Email; IP address; Device Information; Information collected from cookies or other tracking technologies; Social Security Number; Government-issued identification; Bank account and routing numbers; Credit and debit card information; Financial information; Age or Date of Birth; National origin; Disability; Citizenship; Military status; Online shopping cart information; Purchase history; Interactions with their services or sites; Shopping history; GPS information when you give them permission through your device settings; IP-based geolocation; Call recordings when you talk to customer service; Voice identification, when you consent to this biometric method of authentication; Profile pictures you provide; Photo IDs you voluntarily provide to authenticate your account, which they delete immediately upon authentication; Business information, contact emails and phone numbers; Tax IDs; Fraud and risk assessments; and personalization preferences. You can disable or decline some cookies for PayPal’s sites and services; but, since some parts of their service rely on cookies to work, those services could become difficult or impossible to use. For more information regarding PayPal’s privacy policy, please see: PayPal. By using this Site, you consent to the limited processing of data about you by PayPal in the manner and for the purposes set out in their privacy policy. e. Mailchimp Our Site uses Mailchimp to collect personal information submitted by you through contact request forms and to generally contact users of our Site with general communication and promotional offers. The Rocket Science Group LLC d/b/a Mailchimp is apart of the Intuit group of companies and their parent entity is Intuit Inc. For more information regarding Intuit’s privacy policy, please see: Intuit®: Privacy | Privacy Statement. Mailchimp’s Standard Terms of Use can be viewed here: Mailchimp’s Standard Terms of Use | Mailchimp. By using this Site, you consent to the limited processing of data about you by Rocket Science Group LLC d/b/a Mailchimp in the manner and for the purposes set out in their privacy policy and terms of use. f. Google Analytics This Site uses Google Analytics. Google Analytics is a web analytics service provided by Google LLC (“Google”) that uses log files. Google Analytics also places cookies, as described above, on your computer to help analyze how you use our Site. The personal information generated by the cookies will be transmitted to and stored by Google on their servers in the United States. Google will use this information for the purposes of evaluating your use of our Site, developing reports on Site activity for us for the purposes of marketing and advertising, and internet usage. Where required to do so by law, Google may also transfer this information to third parties or to their service partners who process information on Google’s behalf. Google will not associate your IP address with any other data held by Google. Google’s Privacy Policy can be viewed here: Privacy Policy – Privacy & Terms – Google. By using this Site, you consent to the limited processing of data about you by Google in the manner and for the purposes set out above. You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout. Further information concerning the terms and conditions of use and data privacy can be found at https://marketingplatform.google.com/about/analytics/terms/us/ or at www.google.com/intl/en_us/analytics/privacyoverview.html. Article 4 – Changes 4.1 We may update this Privacy Policy from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. We will notify you before we make changes to this policy and give you the opportunity to review and comment on the revised policy before consenting to use our Services. Article 5 – Notice for European Residents 5.1 The European Union’s (“EU”) General Data Protection Regulation (“GDPR”) requires that certain information be provided to data subjects when their personal data is collected. References in this section to terms such as “controller,” “data subject,” “personal data,” “processor,” and “supervisory authority” shall be defined by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016. 5.2 Our legal basis for collecting and using the Personal Information described in this Privacy Policy will depend on the Personal Information concerned and the context in which we collect it. We collect Personal Information from you: Where we need Personal Information to perform a contract with you. Where Personal Information is deemed as being required or mandatory from you to provide to you with the requested service or to enable you to engage in a particular function on our Site. For example, to enable access to the Site or to process your payment for the Subscription. If you choose against providing us with the required information, you will not be permitted to receive the particular service or engage in the desired function;We provide personal data to third parties in accordance with this Privacy Policy, including third party service providers that render services to us by contract.Where the processing is in our legitimate interests as detailed in this Privacy Policy;Where the processing is necessary for us to meet our applicable legal obligations. For example, to provide and update our Site and the services; to improve our services so that we can offer you an even better user experience; to safeguard our services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; orIf we otherwise have your consent, either expressly or impliedly. If you are a European resident, you have the right to: Request access to Personal Information about you.Request correction of the Personal Information that we hold about you.Request erasure of Personal Information about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.Object to processing of Personal Information about you where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom.Request restriction of processing of Personal Information about you. You can ask us to suspend the processing of Personal Information in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful, but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or, you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of Personal Information to you or to a third party.Withdraw consent at any time where we are relying on consent to process Personal Information about you. If you would like to exercise any of the rights listed under section 5.3, the controller of the personal data collected on this Site is Jennifer Cawthorne, Data Protection Officer, and can be contacted by e-mailing hello@little-egg.com. 5.5 Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information. We encourage you to first reach out to us at hello@little-egg.com, so we have the opportunity to address your concerns directly before you do. Article 6 – Choices 6.1 You have several choices available when it comes to information about you: Limit the information that you provide: If you have a Parent/Guardian or Families & Friends account with us, you can choose not to provide the optional account information and profile information. Please keep in mind that if you do not provide this information, certain features of our Site may not be accessible or function as intended.Limit access to information on your mobile device: The operating system on your mobile device should provide you with an option to discontinue our service partners ability to collect stored information or location information. If you choose to limit this, you may not be able to use certain features, like uploading photographs.Opt out of marketing communications: You may opt out of receiving promotional communications from us by clicking the unsubscribe link provided at the bottom of each promotional communication. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.Set your browser to reject cookies: At this time, our Site does not respond to “do not track” signals. However, you can usually choose to set your browser to remove or reject browser cookies before using our Site, with the drawback that certain features of our Site may not function properly without the aid of cookies.Opt-out of our internal analytics program: You can do this by downloading and installing the browser plug-in available under tools.google.com/dlpage/gaoptout. By opting out, you will stop sharing information with our analytics tool about events or actions that happen after the opt-out, while you’re visiting our Site. Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Site. Please keep in mind that we may continue to retain your information after closing your account, as described above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests. Article 7 – Contact 7.1 For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@little-egg.com. Date: Aug 8, 2022