Effective Date: April 24, 2023
Personal Information We Collect
- Information you provide to us. Personal information you provide to us through the Service or otherwise may include:
a. Contact information, such as your first and last name, email and mailing addresses, and phone number.
b. Content you choose to upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload.
c. Correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
d. Payment information, such as payment card details and billing address.
e. Baby and familial information, including information provided in our Size Quiz such as due date, number of children, children’s names, birth or due dates, weight, height, other physical characteristics, and diaper usage information.
f. Profile information, such as your username and password that you may set to establish an online account with us, your interests, and preferences.
g. Transaction information, such as information about payments to and from you, subscription details (including gift recipients), shipping address and other details of products or services you have purchased from us.
h. Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
i. Publicly-available information, including comments describing support for and experience with our websites and information that you or others publish on social media, testimonials, blogs, or other forums, such as tweets, comments, and photographs.
j. Smart changing pad data, if you use our smart changing pad product, including information about a baby’s weight and movement score.
Information we obtain from other third parties. We may receive personal information about you from third-party sources, such as email services that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. We may also obtain your personal information from other third parties, such as advertising partners, referral partners and publicly available sources.
Information Collected by Automated Means. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, may automatically log the following information about you:
i. Device information, such as your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area.
ii. Online activity data, such as information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
f. Referrals/Gifts. Users of the Service may have the opportunity to refer friends or other contacts to us, or gift a subscription to another individual. Please do not submit a referral or provide us with contact details unless you have permission from the recipient to do so.
How We Use Your Personal Information
- To operate the Service. We use your personal information to:
- provide, operate and improve the Service;
- provide information to you or individuals you may refer about our products and services;
- establish and maintain your user profile on the Service;
- send you announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Service and our communications;
- provide support and maintenance for the Service; and
- respond to your requests, questions, and feedback through the Service, email, or our social media platforms.
- For research and development. We analyze use of the Service to improve the Service and to develop new products and services, including by studying user demographics.
- To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”
- For marketing purposes. We may use your personal information to communicate with you about events or contests in which you participate, understand your needs and interests and personalize your experience with the Service and our communications, and send you Coterie-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing communications section below.
- For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; and (d) to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
- With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
How We Share Your Personal Information
c. Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
d. For compliance, fraud prevention and safety. We may share your personal information with law enforcement, government authorities, and private parties as we believe necessary or appropriate for compliance, fraud prevention and safety purposes described in Section 2(e).
e. Other Users of the Service and the Public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name, username, and a link to your user profile along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.
f. Business transfers. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Coterie, financing of Coterie, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Coterie as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
In this section, we describe the rights and choices available to all users.
a. Access or update your personal information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
b. Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected]. You may continue to receive service-related and other non-marketing emails.
c. Opt out of SMS communications. If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our marketing message. You may also text STOP to +1-951-467-4913.
e. Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
i. Browser settings. Changing your internet web browser settings to block third-party cookies.
ii. Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
iii. Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
● Google: https://adssettings.google.com/
● Facebook: https://www.facebook.com/about/ads
iv. Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
● Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
● Digital Advertising Alliance: optout.aboutads.info.
● AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
v. Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
f. Do not track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
g. Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
h. Linked third-party platforms. If you choose to connect to the Service through your email account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
i. User Generated Content. Certain features of the Service may allow you to upload content (e.g., comments or photos) directly to the Service (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Coterie.
Please note that we do not control who will have access to information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the features permitting creation of UGC or what others do with information you share with them. We are not responsible for the accuracy, use or misuse of any such UGC that you disclose or receive from third parties.
Other Sites and Services
The security of your personal information is important to us.We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International Data Transfers
We are headquartered in the United States and may have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.
The Service is not intended for use by anyone under 16 years of age. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will comply with applicable legal requirements to delete it. We encourage parents with concerns to contact us at [email protected].
How to Contact Us
Coterie Baby, Inc.
Attn: Legal - Privacy
188 Grand Street, 2nd Fl #1065
New York, NY 10013
Notice to California Residents
This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. Please note that we may not be able to process your request to exercise the rights listed below if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.
For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) as amended, but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.
● Contact Information may include “commercial information” and “California customer records”
● Demographic Data may include “California customer records”;
● Account Data may include “commercial information” and “California customer records”;
● Correspondence may “commercial information,” “California customer records,” and “internet or other electronic network activity information”;
● Familial information may include “inferences or “physical descriptions”
● Marketing Information may include “commercial information,” “California customer records,” and “internet or other electronic network activity information;
● Profile information may include “commercial information” and “California customer records”
● Publicly-available information may include “commercial information” and “California customer records”;
● Payment information may include “financial information”;
● Transaction information may include “financial information”;
● Content you upload to the Service may include “sensory information, “California customer records” and “internet or other electronic network activity information;”
● Online Activity Data and Device Data include “internet or other electronic network activity information” and “geolocation data.”
● Information we obtain from social media may include “commercial information,” “California customer records,” “internet or other electronic network activity information” and “geolocation data.”
● Information we obtain from third parties may include “commercial information,” “California customer records,” “internet or other electronic network activity information” and “geolocation data.”
We may disclose each of the categories of personal information identified above to the following categories of third parties for a business or commercial purpose: affiliates, service providers, payment processors, advertising partners, third parties designated by you, professional advisors, authorities and others, business transferees, business and marketing partners, other users and the public.
Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the California Consumer Privacy Act.
Your California privacy rights. As a California resident, you may have the rights listed below in relation to information we have collected about you as defined in the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
a. Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months: the categories of personal information that we have collected; the categories of sources from whom personal information is collected; the business or commercial purposes for which we have collected or sold such personal information; the categories of personal information that we have sold or disclosed; and the categories of third parties to whom we have sold or disclosed the personal information.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
b. Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
c. Deletion. You can ask us to delete the Personal Information that we have collected from you.
d. Right to opt-out of the “sale” or “sharing” of your Personal Information for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.
e. Consumers under 16. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
f. Freedom from Discrimination. You are entitled to exercise the rights described above free from unlawful discrimination as prohibited by the CCPA.
Exercising your right to information, access, correction, and deletion. You may submit requests to exercise your right to information, access, correction, or deletion via email to [email protected].
Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information. While we do not sell personal information for money, like many companies, we use services that help deliver interest-based ads to you as described above. The CCPA may classify our use of some of these services as “selling” or “sharing” your Personal Information with the advertising partners that provide the services. You can submit requests to opt-out of tracking for targeted advertising purposes by emailing [email protected]. We sell or share the following categories of personal information with advertising partners: Contact information; Demographic data; Account data; Correspondence; Marketing information; Profile information; Transaction information; Marketing information; Device data; Online activity data; data derived from the above.
Verification of Identity; Authorized agents. We may need to verify your identity in order to process your information, access, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.
Under the CCPA you many enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your CCPA rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
California Shine the light law.
Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to [email protected]. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.