Privacy Policy

Website Privacy Policy

Last Updated: 06/29/2020

We at Giggle Holdings LLC (“Giggle”, “we”, “us”, or “our”) know of the importance of privacy and greatly value the privacy of our customers, website and application users (“Users”, “you”, “your”). We recognize your interest in knowing how information about you is processed. In this Privacy Policy (“Policy”), we describe how we collect, use, store, disclose, or otherwise process information that we obtain about users of our website (the “Site”), and the services available through our Site ( “Services”). Our Services include an e-commerce business that carefully curates baby and child related products in categories including clothing, gear, toys, gifts, giggle-branded products and more. This Policy also informs you about your rights and choices with regard to the information collected about you. Your use of our Services, and any dispute over privacy, is subject to this Policy and any other applicable agreements between you and Giggle, such as our Terms of Use, and include applicable limitations on damages and the resolution of disputes.

 

 

Information We Collect

We collect information about you directly from you, from third parties, and by automated means through your use of our Services. We may combine the information we collect from these various sources. “Personal information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, device, or household. Please see below for more information about the categories of personal information we collect.

Account and Registration. We collect identifiers, such as a name, address, online identifier or username, Internet Protocol address, or email address from your account and registration, including through rewards and loyalty programs. We collect this information directly from you. For example, we collect information from you when you register for an account with us, including your name and email address. We may also ask or allow you to submit additional optional account information, such as postal and/or shipping address, or mobile phone number. You can also sign up to receive emails, newsletters and other special offers from us by submitting your address, email address, and other optional contact information. We disclose this information for business purposes to affiliates, partners, internet service providers, administrative service providers, and payment processors.

Customer Support and Services. We collect personal information contained in customer records, which may include name, address, telephone number, bank account number, credit card number, debit card number, or any other payment and financial information. We collect this information when you request information from us, contact us for customer service or other purposes. For instance we may email you to answer your inquiry. We disclose this information for business purposes to affiliates, internet service providers, administrative service providers, and payment processors.

Content. Our Services may allow Users to submit content to our Services, such as comments, blog posts, reviews, or ratings. We collect identifiers, such as a name, address, online identifier or username, Internet Protocol address, or email address when you submit content. We disclose this information for business purposes to affiliates, administrative service providers, marketing service providers, or data analytics providers.

Surveys. We collect identifiers, such as a name, address, online identifier or username, Internet Protocol address, or email address directly from you if you choose to participate in one of our voluntary surveys. We do not disclose this information to third parties.

Usage of Our Services.  We collect commercial information, which may include records of Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We collect this information directly from you or indirectly (e.g., from observing your actions on our Site). We disclose this information for business purposes to affiliates, administrative service providers, marketing service providers, or data analytics providers.

Other Information from Third Parties. We may also collect information, including personal information about you from third parties, which we may combine with other information we have collected. If it can be used to identify you, we will treat it as personal information. Also, if you take advantage of a third-party [or affiliate] offer through the Services, we may collect certain information from that third party about your order or interaction with them, such as purchase amount and details and credits earned. Please also see the “Third-Party advertisers and Third-Party Analytics” section below for more information about data collected by third parties. We disclose this information for business purposes to affiliates, administrative service providers, marketing service providers, or data analytics providers.  

Usage and Device Data. We automatically collect Internet, technical or other similar network activity, which may include usage and browsing history; device information, including device properties; search history; information on your interaction with our Site; and error logs. We collect this through cookies, web beacons, log files and other methods: including log files, IP address, app identifier, device ID, or advertising ID (“Usage Data”). We may combine Usage Data with other information that we have collected about you, including, where applicable, your user name, name, email address and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information. We disclose this information for business purposes to affiliates, administrative service providers, data analytics providers, and Internet service providers.

 

DATA RETENTION

We will retain your information for as long as needed to provide you Services and to comply with our accounting and legal obligations, resolve disputes, and enforce our agreements. When you place an order through the Site, we will maintain your order information for our records unless and until you ask us to delete this information.

How We Use Your Information

We may use your information, including personal information and content, for the following purposes:

Providing and Improving Our Services. To provide and maintain our Services; to improve our Services; to develop new features, products, or services; to authenticate users; or to perform technical operations, such as updating software.

Customer Support and Service. We use the personal information we collect for customer service and support purposes. For example, if you send us an inquiry we will use your personal information to address and answer your question.  

Personalizing Content and Ads. We may use the information we collect about you to personalize the information and content we display to you, including marketing, promotional and sponsored content, as well as providing you with more relevant ads.

Marketing and Communications. To communicate with you about your account and use of our Services via email and push notification, including to send you product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, promotional contests, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Please see the “Access to Your Information” section or contact us for more information about how to change your communications preferences.

Research and Analytics. To monitor, analyze and understand usage and activity trends, to conduct analytics on photos and images, and for other research, analytical, and statistical purposes.

Protecting Rights and Interests. To protect the safety, rights, property, or security of Giggle, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or our Terms of Use.

Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

How We Disclose Your Information

We may disclose your information, including personal information as described to you at the time of collection or disclosure or as follows:

Users. You may post or upload materials, comments, reactions and other content or information to our Services, collectively “User Content”. Any User Content you post within the Services may be viewable by all other users and Site visitors. This includes comments, reviews, or other content you choose to share on your user profile or blog provided within the Services. We cannot prevent such information from being used in a manner that may violate this Policy, our Terms of Use, the law, or your personal privacy. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.

Partners. If you click an ad or otherwise take advantage of a third party offer in the Services, we may share certain information, including personal information, with that partner to facilitate your interaction with them. Partners are responsible for their own use of your personal information as well as the communications they send to you; you should contact them directly to opt-out of receiving marketing communications and review their respective privacy policies for more information.

Marketing Partners. We also may share your information with certain third parties so that they may send you offers and other information we think you may be interested in. If you don’t want us to share your personal information with our third party marketing partners, you may opt-out by emailing us at info@giggle.com. However, if you opt-out of such ‘third-party-marketing’, this won’t affect information we have already shared, and we may still send you our own marketing and promotional emails about information and third-party ads we think you may be interested in (unless you have opted-out of receiving marketing emails from us).  

Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your information to third-party service providers to process payments on our behalf.

Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries. However, if we do so, their use and disclosure of your personal information will be subject to this Policy.

Business Transfers. We may disclose or transfer your information to another entity in connection with an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer or reorganization, including during assessment and negotiations related to such transactions. If transferred in such a case, your information would remain subject to this Policy or a privacy policy that, at a minimum, protects your privacy to an equal degree as this Policy.

Protecting Rights and Interests. We may disclose your information to protect the safety, rights, property, or security of Giggle, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which Giggle, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or our Terms of Use.

Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.

Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

Cookies and Other Tracking Mechanisms

We and our service providers use cookies, pixels, java script, and other tracking mechanisms to track information about your use of our Site and App. We or our service providers may combine this information with other information, including personal information, we collect about you.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.  

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third-Party Analytics

We may use third-party analytics companies, for example Google Analytics (see privacy policy and opt-out), to evaluate use of our Services. We use these tools to help us understand use of, and to improve, our Services, performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.

Do-Not-Track Signals. The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them. For more information about do-not-track signals, please click here. You may, however, disable certain tracking as discussed in the “Cookies and Other Tracking Mechanisms” section above.

 

Interest-based Ads

We work with third party ad networks, ad exchanges, channel partners, measurement services and others (“third-party ad companies”) to display more relevant advertising on our Services, and to manage our advertising on third party sites, mobile apps and online services. In order to display more relevant ads on our behalf and others, these third party ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information on our Services, on third-party sites and across different devices, which may be linked with certain offline data. They may also collect IP address, device ID, cookie and advertising IDs, and other identifiers, and general location information. These third party ad companies may use this information to provide you more relevant ads and content and to evaluate the success of such ads and content. As a result, our ads may be displayed to you on a search results page or on third party sites.

For example, we may work with the following advertising platforms, among others:

  • Facebook Ads

We also use Facebook to measure your use of our Sites, tailor our Sites to your interests, and improve our products and services. Please note, Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at Facebook.com/about/privacy/. Please click here if you would like to withdraw your consent.  

You can also obtain more information about targeted advertising, and how to opt-out of receiving targeted ads from many third-party ad networks (including Facebook and Google), through the following:

U.S. Users:  www.aboutads.info/choices (Digital Advertising Alliance)

Users in Canada: http://youradchoices.ca/choices/ (Digital Advertising Alliance of Canada)

Opting-out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs. Please note, that opt-out mechanisms are cookie based. So, if you delete cookies, block cookies or use another device, your opt-out will no longer be effective.  

Third-Party Links and Widgets

Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third parties.

Our Sites also may include social media features and widgets (collectively “Widgets”), such as a "share this" or “like” button or other interactive mini-programs that run on our Services. Widgets can be used to provide you specific services from other companies (e.g., displaying the news, opinions, music, etc.). These third party sites may collect your IP address and certain information through the Widgets. Cookies may also be set by the Widgets to enable them to function properly. Widgets displayed on our Sites are not hosted by the relevant third party and are subject to the privacy policies of the third-party company providing the Widget, and not this Policy.

Security

We have taken steps to help protect the personal information we collect. However, no data security measures can guarantee 100% security. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Site. We may post a notice via our Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private.

Accessing Our Sites From Outside Of The United States

If you are visiting our Sites from a location outside of the U.S., your connection may be through and to servers located in the U.S. Any information you provide during your visit will be processed and maintained on our server and other internal systems located within the U.S. You acknowledge you understand that by providing your personal information to us, your personal information (i) will be used for the uses identified above in accordance with this Policy, and (ii) may be transferred to the U.S. as indicated above, in accordance with applicable law.

Marketing Communications

We may send periodic promotional emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

Access to Your Information

You may access, update and remove much of the personal information within your profile, by logging in and updating your profile information accordingly. If you want to stop using your account, you may deactivate it or delete it. When you deactivate an account, you will no longer be able to access it, but the information will not be deleted. We save your profile and receipt information in case you later decide to reactivate your account. Many users deactivate their accounts for temporary reasons and in doing so, ask us to maintain their information until they return to our Services. If you deactivate your account, you will have the ability to reactivate it and restore your profile in its entirety. When you delete an account, your account history and data will no longer be available to you. You should only delete your account if you are certain you never want to reactivate it. Please note that we also may retain certain information about you as required by law or as permitted by law for legitimate business purposes. For example, if you request that we delete your information but we believe that you have violated our Terms of Use we may retain information about you in order to attempt to resolve the issue before deleting it.  

California Privacy Rights

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us their personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use; such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year (so, requests submitted in 2019 would be applicable to relevant disclosures (if any) in 2018). If you are a California resident and would like to make such a request, please submit your request in writing by emailing us atinfo@giggle.com, using the subject line "Request for California Privacy Information – Shine the Light." In your request, please attest to the fact that you are a California resident and provide a current California address. We will reply to valid requests by sending a response to the email address from which you submitted your request. Please note that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.

Starting January 1, 2020, you may be entitled to the below rights:

  • the right to know. You may request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the sale or disclosure for business purposes of your personal information to third parties, and the categories of third parties with whom this information was shared. You may also request a copy of the personal information we have collected, and upon request, we will provide this information to you in electronic form;
  • the right to opt out of the sale of your personal information to third parties. We do not sell your personal information at this time, and we do not sell the personal information of children under 16 years old;    
  • the right to request deletion of your personal information, subject to certain legal exceptions; and
  • the right to not be discriminated against for exercising any of the rights mentioned above.

You can exercise your rights by contacting us using the details set out in the “Contact Us” section below. Whenever feasible for verification, we will match the identifying information provided by you to the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State and must have permission to submit requests on your behalf. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

Children

Our Services are not targeted to children under thirteen (13) years of age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.

Changes to this Policy

This Policy is current as of the Last Updated Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site, and will take steps to notify you of material changes, such as via email or prominent notice on the Site.

Please confirm that this is true and there is a process in place to provide copies of personal information to individuals. The CCPA requires that Personal Information be delivered by mail or electronically. If provided electronically, the information should be portable and in a readily useable format.

Please confirm if personal information is sold. Please see cover email for additional information.

Please let us know if you would like assistance with back-end processing requirements for these requests.For example, for account holders—fresh log-in is required; where non-account holders ask to know specific pieces of information, there is a high bar--this can be done by matching at least three pieces of personal information provided by the consumer with personal information maintained by the business that it has determined to be reliable for the purpose of verifying the individual together with a signed declaration under penalty of perjury that the individual is the consumer whose personal information is the subject of the request. Businesses shall maintain all signed declarations as part of their record-keeping obligations.

Contact Us

If you have questions about this Policy or the privacy aspects of our Services, please contact us at info@giggle.com.