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Privacy Policy

The privacy policy was last revised on October 22, 2021.

Little Passports, Inc. (“Little Passports,” “us,” “we,” or “our”) owns and provides various websites, services, materials and software available at https://www.littlepassports.com and related URLs (the “Site”, and collectively with the services, materials, and software, the “Services”). 

  1. Scope
  2. Personal Information We Collect
  3. How We Use Your Personal Information
  4. How We Share Personal Information
  5. Data Transfers
  6. Your Rights
  7. Your Privacy Rights
  8. Supplemental California Privacy Notice
  9. Supplemental Notice for Nevada Residents
  10. Children’s Privacy
  11. Data Retention and Security
  12. Contact Us

1. Scope

Little Passports respects your privacy and values your trust. This Privacy Policy is designed to help you understand how we collect, use and share your personal information, and to assist you in exercising the privacy rights available to you.

Little Passports reserves the right, at its sole discretion, to change, modify, update, add, or remove portions of this Privacy Policy at any time. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. Please check this Privacy Policy periodically for changes. Your continued use of the Site after the posting of any changes to the Privacy Policy will signify your acceptance of those changes. Please note that this Privacy Policy does not apply to any of the personal information that may be collected and processed by any third-party websites, services, or applications that may be accessible through our Services.

2. Personal Information We Collect

The types of information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable law. Some of the ways that we may collect information include:

(a) Data Collected from You Directly

Account Registration Information

If you choose to register at the Site, we will collect personal information for your account, including your full name, email address, password and/or username.

Purchase Information

If you choose to purchase a subscription to our Services, you we may collect information to enable us to process your order and ship products to you or your child, including your name, your street and/or mailing address, your telephone number, your means of payment, and your child’s full name, birth month and year. We do not store your payment card information, which is stored securely by our payment processor.

Interactive Features

We and others who use our Services may collect personal information that you submit or make available through our interactive features, such as features that allow you to review or rate our Services. Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law,  and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

Surveys

We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.

Sweepstakes or Contests

We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

Job Applications

We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use this information to assess your qualifications.

(b) Automatically Collected Usage and Device Information

When you interact with our site, we automatically collect certain information about how you use our Site, including log files, the type of internet browser you are using, the type of computer operating system you are using, the time and date of your use of the Site, location (derived from IP address), whether you clicked on hypertext links within the Site, pages that you visit before, during and after using our Service, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. If you sign up for our SMS messaging service, we will also collect your messaging history and any information included in those messages.

Cookies and Other Technologies

We and third parties that provide us with content, analytics, advertising, or other services may use different types of technologies to collect information, including cookies, local storage, single-pixel GIFs, web beacons and other technologies (“Technologies”). We use Technologies that are small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that automatically collect certain information whenever you visit or interact with our Sites, Services, applications, messaging, and tools, and to recognize you across devices.

  • Cookies are small text files that are placed on your device to identify your computer to our servers, store preferences, and facilitate and enhance your experience. If your browser is configured to accept cookies, we will use cookies to recognize your computer when you visit the Site so that we can provide you with a better experience and improve the quality of the Site. If you wish, you can configure your browser to disable cookies. If you disable cookies, however, it may impair some functionalities of the Site.
  • A pixel tag is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

If you would like to opt-out of the Technologies we employ on our Site, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits, as described further below.

Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security or allow you to make use of our Services;
  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how you use our Services (see Analytics below);
  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites. If you sign up for our text messaging program, cookies may be used to personalize your experience (e.g. send you personalized text messages such as shopping cart reminders).

Social Features  

Our Site may include social media features such as the Facebook “Like” and Pinterest buttons (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to process information regarding visitor behavior and visitor demographics on some of our Services, and to develop Site content. We use this information to improve to understand how our Services are used, so that we may improve them or develop new Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.

(c) Information we collect from Other Sources

We may obtain information about you from other sources, including through your use of third-party sites and applications. For example, if you access our Services through a third-party application, such as an app store, a third-party login service,or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

Referrals and Sharing Features

Our Services may offer various tools and functionalities that allow you to provide information about your friends through our referral service; third parties may also use these services to upload information about you. In addition, we may collect information that other people provide about you when they use our Services, including information about you when they tag you. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

3. How We Use Your Personal Information

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to fulfil our contract with you and provide you with our Services, such as:

  • Managing your information and accounts;
  • Fulfilling your orders;
  • Providing access to certain areas, functionalities, and features of our Services;
  • Answering requests for customer or technical support; and
  • Communicating with you about your account, activities on our Services, and policy changes.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • Measuring interest and engagement in our Services;
  • Short-term, transient use, such as contextual customization of ads;
  • Improving, upgrading or enhancing our Services;
  • Developing new products and Services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
  • Debugging to identify and repair errors with our Services;
  • Auditing relating to interactions, transactions and other compliance activities;
  • Sharing information with third parties as needed to provide the Services;
  • Enforcing our agreements and policies; and
  • Complying with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

D. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

  • Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
  • Automated Decision Making. We may engage in automated decision making, including profiling to send you personalized messages and cart reminders. Little Passport’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us”
  • De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create.
  • Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend neighbor, or co-worker).

4. How We Share Personal Information With Others

We may share your personal information with the following categories of third parties:

Providers

We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for the provision of the Services, such as payment and transaction processing, customer service activities, IT, and related services.

Business Partners

We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.

Affiliates

We may share personal information with our affiliated entities for our administrative purposes.

Referral or Shared Content

When you request our referral services to forward or share certain content with a friend, such as an email inviting a friend to our Services or sharing certain content from the Services with a friend, we may share that content with your friend.

Advertising Partners 

We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”  

APIs/SDKs

We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfer

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. Data Transfers

Personal information collected via or by Little Passports may be stored anywhere in the world, including but not limited to the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your personal information may be accessible to law enforcement or other authorities pursuant to a lawful request.

If you are located in the European Economic Area, Switzerland, the United Kingdom, or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

6. Your Rights

Notifications/Opt-out and Other Rights

You have the right to opt out of certain uses and disclosures of your personal information. Where you have consented to Little Passports’ processing of your personal information, you may withdraw that consent at any time and opt-out to further processing by contacting us at the address below.

It is Little Passports’ policy to provide notifications, whether such notifications are required by law or are for marketing or other business-related purposes, to users via email notice, written or hard copy notice, or through conspicuous posting of such notice on the Site, as determined by Little Passports in its sole discretion. If you consent, we may also use your email address to send you other messages, including special offers. You may opt out of certain notifications by using the unsubscribe link found at the bottom of the email to opt-out of receiving future emails, changing your account settings, or by sending mail to the following postal address:

Little Passports, Inc.
27 Maiden Lane, Suite 400
San Francisco, CA 94108

We will process your request in accordance with applicable law. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Other Technologies

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings By following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also opt out of data collection by Google Analytics by visiting http://tools.google.com/dlpage/gaoptout.

Whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out in each browser and on each device.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Text Messages

You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

7. Your Privacy Rights

In accordance with applicable law, you may have the right to:

  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine-readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (the “right of data portability”);
  • Request Correction of your personal information Where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
  • Request Deletion of your personal information;
  • Request Restriction of or Object to our processing of your personal information including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes, and request compensation for the damage; and
  • Withdraw your Consent to our processing of your personal information.  Revoking your consent does not affect the lawfulness of any processing based on your consent before its revocation.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

8. Supplemental California Privacy Notice

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Little Passports has collected about them, and whether Little Passports disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by Little Passports

Category of Third Parties Information is Disclosed to for a Business Purpose

Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name , or other similar identifiers.

·       Advertising networks

·       Data analytics providers

·       Service providers

·       Other Users (content you share)

 

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, or description, address, telephone number, ,  financial information.

·       Data analytics providers

·       Service providers

 

Protected classification characteristics under California or federal law

Age, and sex (including gender).

·       Data analytics providers

·       Service providers

 

Commercial information

Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

·       Advertising networks

·       Data analytics providers

·       Service providers

Internet or other electronic network activity

Browsing history, search history, information on a consumer’s interaction with an internet website or advertisement.

·       Advertising networks

·       Data analytics providers

·       Service providers

Sensory data

Audio, electronic, visual, or similar information.

·       Data analytics providers

·       Service providers

·       Other users (your User Content)

 

Inferences drawn from other personal information to create a profile about a consumer

Profile reflecting a consumer’s preferences, and behavior.

·       Advertising networks

·       Data analytics providers

·       Service providers

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

“Sales” of Personal Information under the CCPA

For purposes of the California Consumer Privacy Act, we do not “sell” your personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age, as the term “sell” is commonly understood. That said, we do share information with third-party advertisers for the purpose of promoting our Services. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your information shared by disabling third-party cookies on your device, or by contacting us as set forth in “Contact Us” below.

If you are a California resident, you have the right not to receive discriminatory treatment by Little Passports for the exercise of your rights conferred by the California Consumer Privacy Act.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

As described above in How We Use Your Personal Information (“Referral or Shared Content”), we may offer referral programs or other incentivized data collection programs. For example, we may offer incentives to you such as discounts,promotional items, or credit in connection with these programs, where you provide your personal information in exchange for a reward or provide personal information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. In some instances, the referred party may also receive rewards for signing up via your referral. These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party’s data to us depends on whether the referred party ultimately becomes a User and uses our Services. Said value will be reflected in the incentive offered in connection with each program.

This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly viewable portions of the Services by contacting us directly as set forth in “Contact Us” below or logging into their account and removing the content or information using our self-service tools.

9. Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at privacy@littlepassports.com, or at the address listed in the Contact Us section below, with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

10. Children’s Privacy

Little Passports takes the privacy of children seriously. A parent or guardian may provide information about their child when they are purchasing a Little Passports product, including the child’s name, age, gender, and mailing address. We also offer educational content on a webpage located at explore.littlepassports.com which does not include any cookies or other tracking tools designed to create behavioral profiles or serve retargeted advertising to child users. As such, children who visit explore.littlepassports.com are not tracked or profiled for marketing or advertising purposes.

11. Data Retention

We retain the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

We have implemented technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. Be aware, however, that the Internet is not 100% secure, and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal information for improper purposes. We cannot ensure the security of any information transmitted to us over the Internet, and to the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure of such information.

12. Contact Us

If you have any questions, comments, or concerns regarding this Privacy Policy and/or data practices, please contact us at the following e-mail address, telephone number, or mailing address:

privacy@littlepassports.com

Little Passports, Inc.
27 Maiden Lane, Suite 400
San Francisco, CA 94108
(415) 496-6624

 

Additional clauses for Australian customers

Personal Data We Collect

We do not generally require you to disclose any sensitive information (e.g., details of race, religious belief, sexual orientation or membership of a trade union) to us. If you do provide us with sensitive information for any reason, you consent to us collecting that information and using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Australian Privacy Act 1988 (Cth) (“Privacy Act”) and other relevant laws.

How We Use Personal Information

We will only use and disclose your personal information for the purposes of marketing our Services or services of third-party organizations where you have consented to us doing so, or as otherwise permitted by law.

Does Personal Information leave Australia?

We may disclose personal information outside of Australia to third-party service providers and other selected third parties described above, including those located in the United States. For Australian users, except in some cases where we may rely on an exception under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the Australian Privacy Principles in the Privacy Act in relation to such information.

Children’s Privacy

If a user indicates they are under 15 and we are required to obtain the user’s consent (for example, for the collection of sensitive information), we will seek consent from the user’s parent or legal guardian.

Access or correction of personal information and questions about this Privacy Policy

If you would like to access or correct the personal information which we hold about you, or you have a question or complaint about our use of your personal information please contact us at privacy@littlepassports.com. When contacting us, please provide as much detail as possible in relation to your question, comment or complaint.

We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

Supervisory Authority

If you are based in Australia and you are not satisfied with how Little Passports has handled your data, you may wish to contact the Office of the Australian Information Commissioner.