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Privacy Policy

Privacy Policy

Effective as of February 1, 2020.

Pouch Pet Foods, Inc. d/b/a Pallaby (“Pallaby,” “we,” “our” or “us”) has adopted this “Privacy Policy” to describe how we collect, use and share your personal information in connection with our websites (the “Sites”) and any other online content, tools or services that we control and that link to this Privacy Policy (together with the Sites, the “Service”).

Table of Contents

Personal Information We Collect

Information you provide to us. Personal information you provide to us through the Service or otherwise includes:

Information from third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as data providers; affiliates within our corporate group of companies; business partners, such as joint marketing partners; and publicly accessible sources, such as social media platforms.

Data collected automatically. We, our service providers and our third party partners may automatically log information about you, your computer or mobile device, and your activity over time on the Service and other online services, including:

Some of our automatic collection is facilitated by:

Sensitive personal information. We ask that you not share with us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise. If you do anyway, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection.

Service delivery. We use your personal information to:

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing and advertising. We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

Compliance and protection. We may use your personal information to:

Other purposes with your consent. We may also use your personal information for other purposes described in this Privacy Policy or at the time we collect the information.

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Business partners. Third party companies that we partner with to provide content or services to you or to such business partners.

Advertising partners. Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to you and similar users on their platforms.

Business transferees. Relevant participants in business transactions (or potential transactions), such as corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Pallaby or our affiliates (including, in connection with a bankruptcy or similar proceedings). In any of these cases user information, including personal information, could be one of the assets transferred to or acquired or accessed by a third party.

Service providers. Other companies and individuals that provide services or perform tasks on our behalf to help us operate the Service or our business, such as, for example, customer support, hosting, analytics, email delivery, marketing services and database management services.

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Stripe, and we never physically receive or store your full payment card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your Payment Information in accordance with its own Privacy Policy here: https://stripe.com/privacy.

Professional advisors. Professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities and privacy parties, when we believe in good faith it is necessary or appropriate for the compliance and operations purposes described above.

For other purposes. We may also share your personal information for other purposes described in this Privacy Policy or with your consent.

Your Choices

Marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions located at the bottom of the email or by emailing us at care@pallaby.com. You may continue to receive service-related and other non-marketing emails.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Advertising choices. You can limit use of your information for interest-based advertising by:

The opt-out preferences described above must be set on each device for which you want them to apply. Not all companies that serve interest-based ads participate in the ad industry opt-out programs described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

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.

Declining to provide personal information. If you do not provide information that we need to provide the Service, we may not be able to provide you with the Service or certain features. We will tell you what information you must provide to receive the Service when we request it.

Children

The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

Third Party Sites and Services

The Service may contain links to websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or other online services that are not associated with us. We do not control websites or other online services operated by third parties, and we are not responsible for their actions. Other websites and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

Security

The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

International Data Transfers

We are headquartered in the United States and may use service providers in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Changes to this Privacy Policy

We may update this Privacy Policy at any time. When we make material changes to this Privacy Policy, we will notify you by updating the effective date of this Privacy Policy and posting the modified Privacy Policy. We may also provide notification of any material changes via email if we have your email address, through the Service or in another manner that we believe is reasonably likely to reach you. Any modifications to this Privacy Policy will be effective when posted (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy or our information handling practices, please contact us by email at care@pallaby.com or postal mail at the below address:

Pouch Pet Foods, Inc.

1144 5th Street, #5
Santa Monica, CA 90403

Information for 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. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

How to exercise your information, access and deletion rights. You may submit a request to exercise your information, access or deletion rights by emailing care@pallaby.com or calling us toll-free at (888) 919-0932. We will need to verify your identity to process your information, access and deletion requests and we reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, we may be required or permitted by law to deny your request.

We do not sell your personal information. Based on our current understanding of the CCPA, we do not “sell” your personal information as defined in the CCPA. However, like many companies online, Pallaby uses services provided by Google, Facebook and other advertising companies that track website visitor activity to help deliver interest-based ads to those visitors. We describe this in more detail in the subsection above entitled “Interest-based advertising.” Use of these services may constitute a “sale” of Personal Information under the CCPA where the user has not opted into the tracking.

Personal information we collect, use and disclose. The chart below describes the categories of Personal Information we collect by reference to the categories specified by the CCPA (California Civil Code § 1798.140(o)).

Statutory category of personal information (“PI”)

PI we collect

Source of PI

Business/
commercial purpose for PI collection

Categories of third parties to whom we may “disclose” PI for a business purpose

Identifiers

  • Contact information
  • Profile information

  • You
  • Third party sources
  • Service delivery
  • Research & development
  • Marketing & advertising
  • Compliance & protection
  • Business partners
  • Advertising partners
  • Service providers

Commercial Information

  • Communications
  • Marketing information
  • You
  • Third party sources
  • Service delivery
  • Research & development
  • Marketing & advertising
  • Compliance & protection
  • Service providers

Financial Information

  • Transaction information
  • You
  • Service delivery
  • Compliance & protection
  • Payment processors
  • Service providers

Online Identifiers

  • Device data
  • Online activity data
  • You
  • Third party sources
  • Automatic collection

  • Service delivery
  • Research & development
  • Marketing & advertising
  • Compliance & protection
  • Business partners
  • Advertising partners
  • Service providers

Internet or Network Information

  • Device data
  • Online activity data
  • Third party sources
  • Automatic collection
  • Service delivery
  • Research & development
  • Marketing & advertising
  • Compliance & protection
  • Business partners
  • Advertising partners
  • Service providers

Inferences

May be derived from your:

  • Device data
  • Online activity data
  • Us
  • Service delivery
  • Research & development
  • Marketing & advertising
  • Compliance & protection
  • Service providers