Last Revised: August 23, 2017
littleBits Electronics Inc.
Attn: Customer Service
601 W. 26th Street, Suite M274
New York, New York, 10001
3. A Note About Children. We do not intentionally gather Personal Data (as defined below) from visitors who are under the age of 13. If a child under 13 submits Personal Data to littleBits and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at info[AT]littleBits.cc.
As described in the Privacy Shield Principles, littleBits is accountable for Personal Data that it receives and subsequently transfers to third parties. If third parties that process Personal Data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.
Should you feel that we have not complied with the Privacy Shield principles and the handling of your personal data and we have not been able to remedy your complaint ourselves, you may wish to contact JAMS who is our nominated alternative dispute resolution provider. To obtain more information or to file a complaint, please visit https://www.jamsadr.com/eu-us-privacy-shield.
As further explained in the Privacy Shield Principles, binding arbitration will also be made available to you in order to address residual complaints not resolved by any other means. littleBits is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
5. Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
(a) Information You Provide to Us.
- We may collect information from you, such as your first and last name, gender, e-mail and mailing addresses, professional title, company name, and password when you create an account to log in to our network (“Account”).
- If you use our Services on your mobile device, including through one or more of our Applications, we may collect your phone number and the unique device ID number.
- If you tell us where you are (for example, by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can either uninstall the applicable Application or Applications or deactivate GPS on your mobile device.
- Our mobile homepage lets you store preferences like your location. We may associate these choices with your ID or the mobile device, and you can edit these preferences at any time on our mobile homepage.
- When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
- Certain Services may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
- When you order products or services on our Site, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information. This information may be shared with third parties who will help process and fulfill your purchases. When you submit credit card numbers, that information is encrypted by our payment processor using industry standard technology.
- We retain information on your behalf, such as files and messages that you store using your Account.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- When you post content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) on our Site, the information contained in your posting will be stored in our servers and other users will be able to see it, along with your profile photo and any other information that you choose to make public on your public profile page (“Profile”). The information that you provide in your Profile will be visible to others, including anonymous visitors to the Site.
- When you post messages on the message boards of our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.
- When you participate in one of our surveys, we may collect additional profile information.
- We also collect other types of information that you provide to us voluntarily, such as your computing device operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
- If you participate in a sweepstakes, contest, or giveaway on our Site, we may ask you for your e-mail address and/or home number (to notify you if you win or not). We may also ask for first and last names, and sometimes post office addresses to verify your identity. In some situations we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.
- We may also collect Personal Data on other parts of our Site that state that Personal Data is being collected.
(c) Information Collected via Technology.
- Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- Pixel Tags. We use “Pixel Tags” (also referred to as clear GIFs, web beacons, or web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of website users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user.
- How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable users to opt out of tracking on our site.
- Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
- Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded one or more of our Applications. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use each Application, and information about the type of device you use. In addition, if one or more of our Applications crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Applications. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
(d) Information Collected from You About Others. If you decide to invite a third party to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above. You or the third party may contact us at support[AT]littleBits.cc to request the removal of this information from our database.
(e) Facebook ID. We allow you to use your Facebook login to set up an Account. If you wish to use your Facebook account you are taken to the Facebook website to login to your Facebook account and this information is then shared with us for the sole purpose of setting up your Account.
(f) Information Collected from Third Parties. We may receive Personal and/or Anonymous Data about you from third parties that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site. These third parties may supply us with Personal Data. We may add this information to the information we have already collected from you via our Site in order to improve the Services we provide.
(g) Location Information. If you have enabled location services on your mobile device, we collect your location information to make a map available to the recipients of your messages showing your location. If you do not want this information collected by us, you can disable location services on your mobile device.
6. Use of Your Personal Data
(a) General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you as a user in our system;
- provide improved administration of our Site and Services;
- provide the Services you request;
- improve the quality of experience when you interact with our Site and Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories;
- respond to your inquiries related to employment opportunities or other requests;
- make telephone calls to you, on one or more occasions, as a part of secondary fraud protection or to solicit your feedback; and
- send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of littleBits.
(b) User Testimonials and Feedback. We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent before posting the user’s name along with the testimonial. We may post user feedback on the Site on one or more occasions. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent before posting your name with your feedback. If you make any comments on a blog or forum associated with our Site or Services, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of those blogs or forums, and could be used to send you unsolicited messages. We are not responsible or liable for the Personal Data you choose to submit on these blogs and forums.
(c) Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Site and Services and improve Site and Services navigation. We may use Anonymous Data for any purpose and disclose Anonymous Data to third parties at our discretion.
(a) Third Parties Designated by You. When you use the Services, the Personal Data you provide will be shared with the third parties that you designate to receive such information, including other websites, your friends, relatives, and business associates. Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change your settings at any time as to who has access to your information by going to your account settings and changing your publishing options.
(b) Users. We share your Personal data with other Services users solely for the purpose of providing the Services.
(c) Non-littleBits Service Providers. We may share your Personal Data with non-littleBits service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to littleBits. These non-littleBits service providers are required not to use your Personal Data other than to provide the services requested by littleBits.
(e) Partners. We may provide your Personal Data to trusted partners who work with us or on our behalf and are subject to confidentiality agreements.
(h) Public Profile. Certain parts of the information you provide to us may also be displayed in your Profile. As an essential element of the Site and Services, most of the Personal Data you provide to us when you register or update your Profile is displayed on your Profile. By default, your Profile is public. Your photos, posts, friends, and other content you post to the Site or Services are also meant for public consumption. We may display this content on the Site and Services and further distribute it to a wider audience through third party sites and services. Once displayed on publicly viewable web pages, that information can be collected and used by others. We cannot control who reads your postings or what other users may do with the information that you voluntarily post, so it is very important that you do not put Personal Data in your posts. Once you have posted information publicly, while you will still be able to edit and delete select information on the Site or Services, you will not be able to edit or delete any of such information cached, collected, and stored elsewhere by others (for example, search engines).
9. Your Choices Regarding Information. You have several choices regarding the use of information on our Site and Services:
(b) Cookies. If you decide at any time that you no longer wish to accept Cookies from our Site or one or more of our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all parts of the Site or applicable Services or all functionality of the applicable Services. If you have any questions about how to disable or modify Cookies, please contact us at the contact information provided below.
(c) De-Linking SNS. You may manage the sharing of certain Personal Data with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the privacy settings of the applicable SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your SNS account or mobile device.
(d) Changing Your Personal Data. You may review, update, or correct the Personal Data in your Account (including any imported contacts) by editing your profile via the Services. We will use commercially reasonable efforts to comply with your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
(e) Applications. You can stop all collection of information by an Application by uninstalling that Application. You may use the standard uninstall processes available as part of your mobile device or via the applicable mobile application marketplace or network.
10. Security of Your Personal Data.
- For online payments and/or Automated Clearing House (ACH) payouts, we use the payment services of Braintree (https://www.braintreepayments.com/). We do not process, record, or maintain your credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://www.braintreepayments.com/.
- littleBits is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures designed to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, while littleBits uses reasonable efforts to protect your Personal Data, littleBits cannot guarantee its absolute security.