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
• How We Use Your Personal Information
• How We Share Your Personal Information
• Your Choices
• Children
• Third Party Sites and Services
• Security
• International Data Transfers
• Changes to this Privacy Policy
• Contact Us
• Information for California Residents

Personal Information We Collect

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

• Contact information, such as your first and last name, email and mailing addresses, and phone number;
• Profile information, such as your username, password, relevant pet information, order preferences and any delivery details;
• Communications, such as information you provide when you respond to surveys; participate in market research activities; report a problem with Service, receive customer support or otherwise communicate with us;
• Transaction information, such as the credit card or other payment card details that you use to pay for the Service, and your Service-related billing information and transaction history;
• Marketing information, such your preferences for receiving marketing communications and details about how you engage with them; and
• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

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:

• Online activity data, such as the date and time of your access, visit or use of the Service, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, searches you conduct on our site and information about your activity on a page or screen.
• Device data, such as unique device identifier, media access control address, network information, hardware model, browser type, screen resolution, IP address as well as usage and traffic data and information about how the device interacts with the Service.

Some of our automatic collection is facilitated by:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of tracking user activity and patterns, helping you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.
• Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns. We may use web beacons to track your use of Sites or to collect information about your interactions with our email messages, such as the links you click on and whether you open or forward a message, the date and time of these interactions and the device you use to read emails. Web beacons may be placed on the Sites or Service by third parties such as a social media platform, or an analytics provider in order to support functionality described in this Privacy Policy. We also use web beacons to allow ad networks to provide anonymized and aggregated auditing, research and reporting for us and for advertisers.

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:

• provide, deliver, and customize your use of the Service;
• communicate with you about the Service and to respond to your inquiries, including for customer support;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support and maintenance for the Service.

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:

• Direct marketing. We may send you Pallaby-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Marketing communications” subsection below.
• Interest-based advertising. We may contract with third-party advertising companies and social media companies to display ads on the Service and other sites. These companies may use cookies and similar technologies to try to tailor the ads you see online to your interests based on your activity over time across the Service and other sites, or your interaction with our emails. These ads are known as "interest-based advertisements." You can learn more about your choices for limiting interest-based advertising, in the “Advertising choices” subsection below.

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

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

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 [email protected]. 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:

• Browser settings. Blocking third party cookies in your browser settings using or ad-blocking browser plug-ins/extensions.
• Mobile device settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
  • Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
  • European Interactive Digital Advertising Alliance (for European users): http://www.youronlinechoices.eu/
  • Digital Advertising Alliance: optout.aboutads.info, which lets you opt-out of interest-based ads on websites.

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 [email protected] or postal mail at the below address:

Pouch Pet Foods, Inc.

1144 5^th 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.

• 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 which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

How to exercise your information, access and deletion rights. You may submit a request to exercise your information, access or deletion rights by emailing [email protected] 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)).