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Privacy Policy


Effective April 30, 2019

Thank you for accessing líllébaby.com (the “Site”) operated by líllébaby®, LLC. We respect your privacy and want to protect your personal information. All digital extensions of the líllébaby brand that link to this policy, such as lillebaby.com, are owned and operated by líllébaby, LLC, its parent, its affiliates, agents, and licensors (collectively, "we", "us", "our", or "líllébaby"). By visiting the Site directly or through another site, you accept the practices described in this Policy.

This Privacy Policy does not apply to websites, applications, or services that display or link to different privacy statements, or to those that are owned or operated by third parties. Please review their respective privacy policies to understand how they process your data. This privacy policy does not necessarily apply to any offline collection of your personal information.

1. Children
We respect children’s privacy. We do not knowingly or intentionally collect personal information from children. Elsewhere on the Site, you have represented and warranted that you are either 18 years of age or using the Site with the supervision of a parent or guardian. If you are a child (as defined by applicable law), please do not submit any personal information to us, and rely on a parent or guardian to assist you.

DATA COLLECTION AND USE

2. Types of Data We Collect
We may collect and process data that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements listed in each category are only examples and may change):
    a. Transaction Data.During registration or ordering, you will be prompted to provide certain personal data, including but not limited to your name, shipping and billing address(es), phone number, email address, and credit card number.
    b. Contact Data.Several locations of the Site permit you to enter your email address for purposes including but not limited to: to register for a contest or sweepstakes; to request notification of new brands, product styles, or products; to sign up for email newsletters and special offers; or to create an account.
    c. Site Data. We collect the Internet URL from which you access the Site. We may place cookies, web beacons, or other trackers on your browser; see Cookies and Other Technology below for more information. We may also log your Internet protocol address, Internet service provider, and date/time stamp.
    d. Review Data. You may choose to submit a product review on our site or others. If you post a review, we may ask for your email address and geographic location. After placing an order on the Site, you may receive the opportunity to volunteer feedback on your experience.
    e. Offline Data. We also may collect information offline, for example if you call us to place an order or to ask questions. You might also send us a letter including personal information, and this Policy does not discuss or try to predict all such possible Personal Data submission methods or uses.

     

    How We Use Your Data


    Transaction Data:We use Transaction Data for billing purposes, to fulfill your orders, to communicate with you about your order and about the Site, and for internal marketing purposes. If we encounter a problem when processing your order, we may contact you using Transaction Data. We always permit you to unsubscribe or opt out of future emails, but because we have to communicate with you about orders that you choose to place, you cannot opt out of receiving emails related to your orders.

    Contact Data:

      a. Sweepstakes.Your participation in a contest or sweepstakes is completely voluntary, so you have a choice whether to participate and disclose information to us. We use this information to notify contest and sweepstakes winners and to award prizes. We may post on the Site or our social media sites the names and cities of contest and sweepstakes winners. By entering a contest or sweepstakes, you may opt in to receive our email newsletter and special offers; your choice will be disclosed in the official rules governing the contest or sweepstakes. 
      b. Marketing Communications. We use your Contact Data for marketing emails if you have agreed to receive such emails. For example, if you have chosen to provide your Contact Data, we may send you surveys, offers, and other promotional materials related to our products, special offers for account holders, and for other direct marketing purposes. We do this to promote our products and issue our direct marketing.
      c. Other Communications. We may send you a confirmation email when you register with us. We may send you a service-related announcement on the rare occasions when it is necessary (for example, if we must temporarily suspend a service for maintenance).


      Review Data: If you submit a review, your geographic location may be visible to other users (your email address will be kept private). Any Personal Data that you submit as part of the review can be read or used by other visitors to the Site. We are not responsible for any Personal Data that you choose to submit as part of your review. We believe you can post a helpful review without disclosing any unnecessary personal information.

      Site Data: We may internally use your Site Data to improve the Site’s content and layout, to improve outreach, for our direct marketing, and to determine a general geographic and demographic profile of visitors to the Site. When you interact with the Site, we also use Site Data to understand what you like and don’t like in order to improve the Site. Finally, we use Site Data for system administration, order verification, internal marketing, and system troubleshooting purposes.

      Offline Data: When someone calls us, we will ask only for the personal information we need in order to place the order or to answer the question. When we need to store information (such as order information), we will enter it into our database through SSL encryption (see Data Security for more information). If you fax something to us, we will act upon the fax and then either store it in a locked repository or we will shred the fax if there is no need to retain the information.

      Behavioral Advertising: We may use third-party advertising companies to help tailor site content to users or to serve ads on our behalf off the Site. These companies may employ cookies and web beacons to measure advertising effectiveness (such as which web pages are visited or what products are purchased and in what amount).

      For example, Facebook collects certain information via cookies and web beacons to determine which web pages are visited or what products are purchased.

      The parties that control the processing of Personal Data for behavioral advertising purposes may build a profile of you containing this information, and may be able to identify you across sites, devices, and over time. These services may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for a good or service you were shown in an advertisement. See your Rights and Choices below, or for example Facebook or Twitter’s privacy policies, for information about how you can limit or opt out of this processing.

      Consent: We may use any Personal Data you give us by consent in accordance with that consent.

      Support: We use information you give us in connection with your support requests, for example, to help solve issues, troubleshoot the product, manage your account, or respond to your inquiries.

      4. Data Acquisition and Sharing
      a. We acquire Review Data from Bazaar Voice. We acquire anonymized analytics data on your interactions with our marketing affiliates, including Google, Bing, Babylist, and ShareASale, via cookies and similar technologies. We may process whatever data you choose to share with us on social media sites.

        We may share data with the following types of recipients:

        b. Third Party Service Providers.In connection with our general business operations, Site improvements, to enable certain features, and in connection with our other legitimate business interests, we may share your Personal Data with service providers or sub-processors who provide certain services or process data on our behalf. For example, we may use such third parties to contact customers who have not checked out to follow up on abandoned shopping carts or to see if there was a problem with use of the Site. The third-party service providers or sub-processors are not allowed to use Personal Data except for the purpose of providing these services. Like promotional or special offers that we may send to you, you may opt out of receiving communications like abandoned cart reminders at any time by simply unsubscribing from this service. Simply click the unsubscribe link at the bottom of our email and you will be able to manage and/or remove your account information. See the Data Processor List below for more information.
        c. Affiliates.In order to streamline certain business operations and develop products that better meet the interests and needs of our customers, and to inform our customers about relevant products and other news, we may share your Personal Data with any of our current or future affiliated entities, parent companies, or subsidiaries.
        d. Legal Obligations. We may disclose Personal Data in response to requests from law enforcement officials conducting investigations; subpoenas; a court order; or if we are otherwise required to disclose such information by law. We also will release Personal Data where disclosure is necessary to protect our legal rights, enforce our Terms of Use or other agreements, or to protect ourselves or others.
        e. Corporate Events. We may acquire or merge with, or be acquired by, another company. We might sell or dispose of some or all of our assets. If that happens, your Personal Data may be disclosed to another company, but that disclosure will be subject to the Privacy Policy then in effect.
        f. Marketers. In order to deliver certain advertisements and develop better products, we may share certain Personal Data collected from our Site (as described in Cookies and Other Technology below) with trusted third parties for marketing, advertising, or similar commercial purposes. We may also share non-personal information, such as the number of daily visitors to a particular web page or the size of an order placed on a certain date, with advertising partners. 

         

        5. Cookies and Other Technology 
        “Cookies” are small pieces of information that a website stores on your computer while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (most of which have an expiration date, based on the purpose of the cookie, at which point they self-delete) to provide you with a more personal and interactive experience on our Site. You may remove persistent cookies by following Internet browser help file directions. Web beacons are electronic images that we use on our Sites and in our emails that, when loaded, provide us with information, such as where users navigate on a Site, or whether an email is opened. See below for your choices regarding these technologies.

        We use generally use cookies and similar technologies as follows: 
          • for “essential” or “functional” purposes, such as to enable various features of the Site like remembering passwords or staying logged in during your session;
          • for social media integration e.g. via third-party social media cookies, when you share information using a social media sharing button or “like” button on our Site, or when you engage with our content on or through a social networking website such as Facebook or Twitter;
          • for analytics purposes, consistent with our legitimate interests in how our Site is used or performs, how users engage with and navigate through the Site, what sites users visit before visiting our Site, how often they visit our Site, whether an email was received or opened, and other similar information;
          • subject to any consent required by law, for the purpose of displaying advertisements via retargeting to those users who have visited our Site, or for targeting advertising to visitors to our Site; and
          • subject to any consent required by law, for the purpose of analyzing your feedback on our products on other platforms.
          6. Data Processor List

            Provider

            Function

            Data We Share

            Privacy Information

            Geo

            Shopify

            Storefronts and orders

            Transaction Data, Contact Data

            Shopify Privacy Policy

            U.S.

            CloudFlare

            Media asset caching

            Site data (anonymized)

            Cloudflare Privacy Policy

            U.S.

            ZenDesk

            Customer Support

            Support Data

            ZenDesk Legal

            U.S.

            BazaarVoice

            Feedback

            Review Data; Site Data (web beacon)

            BazaarVoice Privacy Policy

            U.S.

            MailChimp

            Email marketing

            Contact Data, Site Data (web beacon)

            MailChimp Privacy Policy

            U.S.

            ShareASale

            Affiliate marketing

            Site Data (cookie)

            ShareASale Privacy Policy

            U.S.

            Babylist

            Affiliate marketing

            Site Data (cookie), account signup data

            Babylist Privacy Policy

            U.S.

            Weber Logistics

            Shipping/3PL

            Transaction Data

             

            U.S.

            Google

            Web Analytics and Remarketing

            Site Data (cookies)

            Google Privacy Policy

            U.S.

            Bing

            Remarketing

            Site Data (cookie)

            Bing Privacy Policy

            U.S.

            Facebook

            Web analytics, remarketing, site usage

            Review data, Site Data (cookie)

            Facebook Privacy Policy

            U.S.

             


            RIGHTS, CHOICES, & RETENTION

            7. Rights and Choices 
            You may exercise the below Rights and Choices by emailing us at privacy@lillebaby.com or by calling us toll-free at (855) 554-5531. Our physical mailing address is below.

            a. Your Rights.Subject to the rights granted to other individuals, and our rights to limit or deny access/disclosure under applicable law, you have the following rights in your Personal Data. We may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to prove your identity. Note: we may not have access to or control over all or some Personal Data controlled by others. Please contact these third parties directly for data rights requests regarding information these third parties control, and we will assist the you as appropriate in the fulfillment of your request. 

            Access:

            You may receive a list of your Personal Data that we process to the extent required and permitted by law.

            Rectification:

            You may correct any Personal Data that we hold about you to the extent required and permitted by law.

            Erasure:

            To the extent required by applicable law, you may request that we delete your Personal Data from our systems, subject to any legal requirement that we keep such data, such as for accounting purposes, warranty claims, security, or litigation. You may request erasure of your Contact Data by emailing us at privacy@lillebaby.com.

            Data Export:

            To the extent required by applicable law, we will send you a copy of your Personal Data in a common portable format of our choice.

            Objection:

            Where we process data in accordance with our legitimate interests, you can object to that processing to the extent allowed by law.

            Regulator Contact:

            You have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.

             

            b. Your Choices.You may use some of our Site without providing any Personal Data, but you may not be able to access certain features or view certain content. You have the following choices regarding the Personal Data we process:

              Consent:

              If you consent to processing, you may withdraw your consent at any time, to the extent required by law.

              Direct Marketing:

              You may opt out of or withdraw your consent to direct marketing communications. You may cease direct marketing from us by clicking the unsubscribe link in any promotional email we send you.

              Cookies & Tech:

              If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using our cookie banner or by using your browser’s settings menu. Please note this does not necessarily opt you out of being delivered advertising. You may continue to receive generic ads. You must opt out of third party services directly via the third party. You may view a list of other third party service providers who collect information, and/or opt out of such collection of information about you, by visiting https://www.networkadvertising.org/choices/ or https://www.aboutads.info/choices.
              You may opt out as follows: 

              ·       Google Analytics (here)

              ·       Bing (here)

               

              8. 
              8. Data Retention 
              Subject to the earlier exercise of your Rights and Choices, we will store your Personal Data as long as you have an account on the Site. We may keep your email as long as you do not request its deletion. We will store your other Personal Data as long as we deem reasonably necessary to provide our goods and services, according to internal policy. Cookies remain on your browser for varying amounts of time; to see how long each cookie is stored, please visit a cookie tracker site, such as cookiebot.com. We are developing ways to retain your data for shorter periods and will update this Privacy Policy accordingly.

                INTERNATIONAL TRANSFERS AND EU USERS

                9. International Transfers 
                We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. The U.S. does not provide the same legal protections guaranteed to Personal Data in the European Union. Accordingly, your Personal Data may be transferred to the U.S. pursuant to either your implied or express consent, as necessary to provide a service or functionality you request, or for the fulfillment of a contract. Contact us for more information regarding the mechanisms to ensure adequate protection of data subject to EU Law.

                10. EU Users 
                líllébaby®, LLC is the data controller for Personal Data collected under this Privacy Policy. In certain cases (e.g. when we partner with shippers) our partner may be a joint controller with respect to certain Personal Data we provide it. The legal bases of our processing of your Personal Data are in the table below. 

                 

                Processing purpose

                Legal Basis

                Use:
                · Analytics
                · Marketing
                · Behavioral Marketing
                · Support
                · Cookies and Other Technologies

                Disclosure:
                · Third Party Service Providers
                · Marketers
                · Corporate Events

                These processing activities are within our legitimate interests, including without limitation:

                ·       Direct marketing

                ·       Personalization and customization of the Site for individual users

                ·       Determining the effectiveness of marketing campaigns

                ·       Creating, supporting, providing, and supporting innovative products; and

                ·       Securing our Site and network, investigating suspicious activity or violations of our Terms of Use or policies; and protecting the safety of Personal Data, including preventing exploitation or other harms to which users may be particularly vulnerable.
                We balance our interests with any potential impact on you when we process your Personal Data for our legitimate interests. You may object to this processing as permitted by applicable law.

                Disclosure:
                Legal Disclosures

                Processing is necessary to comply with our legal obligations, for example, tax laws, fraud reporting, etc.

                Upon your request to withdraw consent, we will (a) correct or update your Contact Data; (b) stop sending emails to your email address; and/or (c) delete your account to prevent any future purchases through that account. You can make these requests at the contact us section on the Site, by calling líllébaby’s Customer Service Team at (855) 554-5531, or by emailing your request to privacy@lillebaby.com.

                Use:
                · Cookies and Other Technologies

                Consent

                Use:
                · Transaction Data 

                 

                Disclosure:
                · Third Party Service Providers
                · Marketers

                We use your Transaction Data to complete the transactions you request. We share your email for direct marketing only with your consent.


                11. California Residents

                  Residents of California (and others to the extent required by applicable law) may request a list of Personal Data we have disclosed about you to third parties during the twelve months preceding your request. That list is also above in the Data Processor List. We do not sell your Personal Data; however, that to the extent the placement of cookies and other tracking technology on your browser may constitute a sale of Personal Data, we disclose such activity above and you may cease this activity at any time by following the procedures outlined in Rights and Choices.

                  In addition to the right to opt-out of sale of Personal Data, California residents have the right to Access and Erasure of their Personal Data from our systems as outlined in Rights and Choices. California Residents also have the right not to be discriminated against by virtue of their exercise of any of their above rights. If you feel as if you have been discriminated against because of a valid rights request you made to us, please contact us toll-free at (855) 554-5531 or email us at privacy@lillebaby.com.

                  12. Data Security

                    We use appropriate organizational, technical, physical, electronic, and administrative procedures to safeguard the confidentiality of your Personal Data, including Secure Sockets Layer (“SSL”) for all financial transactions through the Site. We use SSL encryption to protect your personal information online, and we also take several steps to protect your personal information in our facilities. Only employees who need access to your personal information to perform a specific job are granted access to your Personal Data. 

                    While we use industry-standard precautions to safeguard your personal information, we cannot guarantee complete security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us is compromised), please immediately notify us of the problem.

                    13. Updates to this Policy

                      If we change or update this Privacy Policy, we will post changes and updates on the Site so that you will always be aware of what data we collect, use and disclose. We encourage you to review this Privacy Policy from time to time. If you have any questions about the Privacy Policy, please contact us at our physical address, email or phone at the following:

                      líllébaby, LLC
                      700 12th St Suite 220 
                      Golden, CO 80401
                      privacy@lillebaby.com
                      Tel.: (855) 554-5531

                       

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