Our Website contains links to other websites for your convenience and reference. We are not responsible for the privacy practices or the content of those sites.
- Right to Withdraw Consent. You have the right to withdraw your consent at any time, in accordance with Section 12 (Your Right to Opt-Out; Object to Processing; Deleting Information).
- The Information We Collect. To provide our Services, and to otherwise conduct our business via the Website, we rely on information provided by, and collected from, our users. This information is collected in order to provide benefits and Services to you and to continue to improve and enhance our Service offerings. This information may include, but is not limited to, that which you provide voluntarily through your interactions with the Site, as well as information about how you use and navigate through the Site. This information consists of the following:
- Personally Identifiable Information. We collect certain information that identifies you as an individual (collectively, “Personally Identifiable Information“). The Personally Identifiable Information we collect may include the following:
- Full Address
- Phone Number
- Your device and/or hardware ID for your mobile device; and
- Financial account information (collected by our Payment Processor if you purchase products)
[Note to draft: Is the above all correct? Is there any other Personally Identifiable Information that is collected?]
- Online Activity Information. We may also collect technical and device-related information through our Website and third party analytics tools that we use (collectively, “Online Activity Information“). Sometimes Online Activity Information can be associated with your Personal Information, in which case we will treat it as Personal Information (as described in Section 2.4 (Treatment of Combined Information), otherwise we consider, and treat, Online Activity Information as Anonymous Information.
- Anonymous Information. Our Website also collects, processes, and/or uses information that does not identify you or your devices, including Personally Identifiable Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information“). Information that meets these criteria might include, for example, demographic information, statistical information (e.g. page views and hit counts), and general tracking information.
- Treatment of Combined Information. If we combine Online Activity Information or Anonymous Information with Personally Identifiable Information, we treat the resulting combination as Personally Identifiable Information.
- How We Collect this Information. We collect the above information through the following means and technologies:
- Registration. In order to provide you with certain Services, we need to collect certain Personally Identifiable Information, including those specified in Section 3.1 (Personally Identifiable Information). For example, when you register to create an account for making purchases or to use certain password-protected Services or areas on our Website, you must provide a variety of Personally Identifiable Information to us in connection with creating a user account.
- Contacting Us. You can contact us via the Site with questions or comments – for example, you can contact us to learn more about Naani’s products and Services. In order to communicate with us, you must provide certain Personally Identifiable Information.
- User-Generated Content. We give you the ability through the Website to engage with us and with others in public exchanges, and this may include opportunities for you to provide comments, reviews, recommendations, and other input via the Website (collectively, “User-Generated Content“). Please understand that, if you include Personally Identifiable Information in User-Generated Content that you post to public exchanges on our Website, others will be able to read, collect, re-publish, and otherwise freely use the Personally Identifiable Information. We are not responsible for Personally Identifiable Information you decide to include in User-Generated Content that you post in public forums, and we will not take down, remove, or edit User-Generated Content, except as required by Applicable Law. If you include in your User-Generated Content any Personally Identifiable Information relating to others, you represent that you have full permission and authority to do so.
- Requesting Information. You can request information directly from Naani via the Site. To do so, you must provide certain Personally Identifiable Information, such as your name, your mailing address or email address, other specified contact information, and a description of the information you are requesting.
- Newsletters and Special Offers. You can provide us with Personally Identifiable Information so that we can send you (i) newsletters about Naani, our Services, and information about issues that we believe may be of interest to you, and (ii) special offers about our products and Services.
- Beacons and Tags. The Website may use certain data collection technologies that rely on (i) beacons; (ii) pixel tags and object hyperlinking tags, and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to tell us what parts of our Website have been visited or to measure the effectiveness of searches that users perform on our Website. These technologies also enable us to send email messages in a format users can efficiently read, to learn whether these email messages have been opened, and to help ensure, for example, that our messages are of interest to our users. These technologies provide us with Anonymous Information, Online Activity Information and, in certain instances, Personally Identifiable Information.
- Device Identifiers; Logs; IP Addresses. To determine whether your device is supported by our Website, we may collect certain information about your device and network, including your IP address, your operating system and browser, your device model, information about your use of the Website, as well as the presence of any software that our Website may require to operate with your device, or other third party software or mobile apps on your device. We automatically receive and record this information in log files, and this is generally Online Activity Information.
- Click-Throughs. We may send email messages or display links that use a “click-through URL” linked to our Website or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information and Online Activity Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.
- To enable and support security features, prevent fraud, and protect your data from unauthorized access.
- To enable features and help us provide you with personalized content.
- To analyze how you use the Website and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached the Website.
- Third-Party Cookies. We use the following third-party Cookies on the Website:
- [Please provide a list of cookies used on the Website].
- Opting Out. You can control and/or delete cookies as you wish – for details, see http://www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as intended by Naani.
- How We Use this Information. We use the information we collect or process, including Anonymous Information, Online Activity Information, and Personally Identifiable Information, as permitted under Applicable Law, including where the use is based on (i) the consent you provide to us at the point of collection as set out in Section 2.2 (Consent by Registered Users); (ii) performance of our agreement to provide you with the Services; (iii) compliance with our legal obligations; and/or (iv) our Legitimate Interests, as well as a third party’s Legitimate Interests. More specifically, we use the information we collect for some or all of the following:
|Our Use of the Information||Bases for Our Use|
|To provide you with the information and Services you request and, specifically, to allow us to send you information via email||Performance and management of our agreement with you|
|To allow you to post User-Generated Content||Performance and management of our agreement with youYour Consent|
|To respond to your inquiries and fulfill your purchases||Performance and management of our agreement with you|
|To customize your visit to and use of the Website||Our Legitimate Interests|
|To determine which Services and content (including marketing content) might interest you||Your consentOur Legitimate Interests|
|To inform you of products and Services that we think would be appealing to you, whether the products or services are provided by us or by others and whether the products are services are available via our Website or via some other channel (including channels operated by third parties); this includes information in the form of recommendations and endorsements that we might provide||Your consentOur Legitimate Interests|
|To enable our affiliates and sponsors to inform you of their products and services that may be of interest to you through their own direct marketing activities||Your consentOur Legitimate Interests|
|To track access to and use of our Website, and conduct data and other analyses, including anonymization and aggregation of Personally Identifiable Information||Our Legitimate Interests|
|To perform internal administration, auditing, operation, and troubleshooting for our Website||Our Legitimate Interests|
|To engage in the activities specified in Section 6 (How We Share This Information)||Our Legitimate InterestsCompliance with our legal obligationsPerformance and management of our agreement with you|
|To evaluate and improve our Website and our communications, and to develop and test new services and content||Our Legitimate Interests|
|To comply with Applicable Law||Compliance with our legal obligations|
Note that when determining the bases for our use of your information, we rely on what we consider to be the most appropriate basis, even if there are multiple bases available in connection with our use.
- How We Share this Information. We value your privacy, and we share the information we collect only in the manner set out below.
- Our Service Providers. We engage third parties to perform functions on our behalf, and these may include maintaining the Website, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personally Identifiable Information, Online Activity Information, and Anonymous Information as applicable. The following are examples:
- We may use service providers: (i) to fulfill your orders; (ii) to provide customer service (where applicable) and facilitate payment; (iii) to process and distribute email or SMS messaging; and (iv) to manage promotions, special offers, and similar activities. These service providers generally require access to your Personally Identifiable Information in order to perform these services.
- We may use analytics service providers to assist us in understanding and using Online Activity Information and other information that we collect via the Site. A service we use in this regard is Google Analytics, and information concerning how Google uses the information is available at https://policies.google.com/privacy/partners, and opt-out options specific to Google Analytics are available at https://tools.google.com/dlpage/gaoptout.
- We may use service providers to anonymize and aggregate Personally Identifiable Information in order to generate Anonymous Information.
- We may engage service providers to analyze the interests and attributes of our users and, using techniques based on Anonymous Information and Online Activity Information, identify others who might share those interests and attributes. We then use this information to reach out to relevant market segments to provide them information concerning the Website.
- Online Activity Information may also be used by our advertising service providers to support Online Behavioral Advertising, or Interest-based advertising as it is sometimes called. If you would like to learn more about Online Behavioral Advertising, please visit the “For Consumers” page on the AboutAds website. If you prefer that our advertising service providers do not know which pages you viewed on our website, you can opt-out on the “Consumer Choice Page” also located on the AboutAds website. Note: If you opt out of Online Behavioral Advertising, you may still receive online advertising from Naani. Opting out from a specific advertising provider means that the ads you do receive will not be based on your preferences or behavior. Also, In order for Online Behavioral Advertising opt-outs to work, your browser must be set to accept cookies. Because the opt-out is registered for the specific computer and browser you use when submitting the opt-out, you will need to opt-out again if you delete the cookies from your computer, buy a new computer, access our website from a different computer, login under a different screen name, or change web browsers.
We do not permit our service providers to use the Personally Identifiable Information we give them for any purpose other than providing services to us.
- Questions of Harm; Legal Process. We may disclose your Personally Identifiable Information and Online Activity Information to third parties, including law enforcement agencies, attorneys, and private investigator organizations, where it is necessary, or where we have a good faith belief that it is necessary:
- To comply with legal process;
- To protect and defend our rights and property, including the Website and associated content;
- To protect against misuse or unauthorized use of our Services;
- To protect the personal safety or property of Website users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and
- To cooperate with public and government authorities including, where required, authorities outside your jurisdiction.
While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personally Identifiable Information, we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.
- How We Safeguard the Information We Collect. We recognize the sensitivity of our users’ Personally Identifiable information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this Information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personally Identifiable Information in accordance with Applicable Law.
- Our Retention of Data. We retain Personally Identifiable Information for the period of time necessary to fulfill the purposes for which we obtained the Personally Identifiable Information and consistent with Applicable Law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
- Accuracy and Minimization of Data. We take reasonable steps (i) to maintain the accuracy of the Personally Identifiable Information we process, and (ii) to limit the Personally Identifiable Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.
- Accessing and Updating Your Information. If you would like to review, correct, or update the Personally Identifiable Information that you have provided to us, or if you would like to request an electronic copy of this Personally Identifiable Information for purposes of transmitting it to another company (to the extent Applicable Law provides you with this right to data portability) you may make such requests by us as provided in Section 21 (Contact Us).
- Your Right to Opt-Out; Object to Processing; Deleting Information
- Unsubscribing to Email or Third Party Marketing. If you no longer wish to receive email messages from us or to have your Personally Identifiable Information shared by us with our sponsors for their own marketing purposes, you can opt out of such uses by either (1) following the “unsubscribe” instructions located near the bottom of each email message, or (2) contacting us as provided in Section 21 (Contact Us).
- Objections. If you object to our processing of your Personally Identifiable Information, and a request for us to delete this Information is not, in your view, sufficient, please contact us as provided in Section 21 (Contact Us).
- Advisory Regarding Participation by Children and Teens. Under U.S. Federal Law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONALLY IDENTIFIABLE INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.
- Notice of Privacy Rights to California Residents. The following provisions of this Section 17 (Notice of Privacy Rights to California Residents) apply if you are a California resident.
- Shine the Light Law. California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes.
- California Consumer Privacy Act. Naani makes the following disclosures regarding the California Consumer Privacy Act:
- No Financial Incentives. Naani does not provide a financial incentive or a price or service difference to individuals in exchange for the retention or sale of their Personal Information. We may send offers to those individuals subscribing to our marketing communications and, unless an individual has opted out of such communications, the individual will continue to receive such communications irrespective of whether a disclosure, deletion, or “Do Not Sell” request has been submitted. Naani does not offer financial incentives to deter consumers from making such requests. Naani will not discriminate against any consumer for exercising their privacy rights, including those provided by applicable law.
- Consumer Reporting. Naani will endeavor to report consumer request metrics when they become available.
- Questions. If you have any questions about our privacy practices, including in connection with the California Consumer Privacy Act, please contact us as directed in Section 21 (Contact Us).
- Do Not Track Notice. Our Website does not change its behavior when receiving “Do Not Track” signals from browser software.
- Complaints. We want your feedback. If you have a suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 21 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority.
- “Applicable Law” means statutes, regulations, and any other laws that apply to the Website, the Services or the Website.
- “Legitimate Interest” means that there is a good reason for the processing your Personally Identifiable Information, and that the processing is carried out in a way that minimizes impacts (if any) on your privacy rights and interests. The term “Legitimate interest” also refers to our use of information in ways that you would reasonably expect, based on your relationship to us. For example, there is a Legitimate Interest in collecting and processing your Personally Identifiable Information: (i) to safeguard our Website, networks, content, and related information and resources; (ii) to administer and generally conduct our business; and (iii) to prevent fraud.