privacy policy

Version 2.0

Last Revised: August 23, 2017

littleBits Electronics Inc. (“littleBits” or “we” or “us” or “our”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the information we collect from users of our website, located at littleBits.cc, our mobile applications (each such application, an “Application”), and our widgets (our website, Applications and widgets, collectively, the “Site”) and online services (“Services”).

1. Questions; Contacting littleBits; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:

littleBits Electronics Inc.
Attn: Customer Service
601 W. 26th Street, Suite M274
New York, New York, 10001
(917) 464-4577
info[AT]littleBits.cc

2. User Consent.  By visiting the Site or using our Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use, and disclosure of your information in accordance with this Privacy Policy.

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.

4. A Note to Users Outside of the United States. If you are located outside the U.S., by visiting the Site or using our Services and providing us with your Personal Data, you acknowledge and agree that your Personal Data may be processed (1) for the purposes identified in the Privacy Policy and (2) in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your Personal Data, you consent to such transfer.

littleBits complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall take precedence. To learn more about the Privacy Shield program, the Privacy Shield Principles and to view our certification, please visit www.privacyshield.gov.

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.

(b) Information You Provide to Facebook and other Social Networking Sites (“SNSs”). The Site and certain Services allow users to access Facebook to interact with friends and to share on Facebook, including through the Facebook Wall and friends’ News Feeds. If you are already logged into the Services and Facebook or another SNS, when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to merge your profiles. If you are already logged into the Site or Services but not logged into Facebook or another SNS that we support, when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to enter your SNS credentials or to “Sign Up” for the SNS. By proceeding, you are allowing the Site and Services to access your information and you are agreeing to the Facebook or other SNS’ Terms of Use in your use of the Site and Services. Conversely, if you are not currently registered as a user of the Site or Services, and you click on “Sign in” using Facebook or another SNS that we support, you will first be asked to enter your Facebook or SNS credentials and then be given the option to register for the Site or Services. In this case, we may receive information from Facebook or another SNS to make it easier for you to create an Account on the Site or Services and show our relevant content from your Facebook or SNS friends. Once you register on the Site or Services and connect with Facebook or another SNS, you will be able to automatically post recent activity back to Facebook or the other SNS. Any information that we collect from your Facebook or other SNS account may depend on the privacy settings you have with that SNS, so please consult the SNS’s privacy and data practices.

(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.
  • Log Files. As is true of most websites, our Site and Services gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site and Services, track users’ movements around the Site and Services, gather demographic information about our user base as a whole, and better tailor our Site and Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
  • Cookies. Like many online services, our Site and Services use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor your experience with us to meet your special interests and needs.
  • 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.
  • Analytics Services and Interest-Based Advertising. In addition to the tracking technologies we place, other Persons may set their own cookies or similar tools when you visit our Site. This includes third party analytics services, including Google Analytics (all such analytics services, “Analytics Services”), that we engage to help analyze how users use the Site and Services, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Site and Services. The information generated by the Cookies or other technologies about your use of our Site and Services (all such information, the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Site and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes stated above. For a full list of Analytics Services, please contact us at support[AT]littleBits.cc. We may also partner with advertising companies to support our marketing efforts, including by serving you advertisements better tailored to your likely interests. If you don’t want to take advantage of these services, you may be able to opt-out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/, or if you are located in the EU, http://www.youronlinechoices.eu/.

(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.

7. Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

(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.

(d) Affiliates. We may share your Personal Data with our parent company, subsidiaries, joint venturers, or other entities under common control with us (collectively, “Affiliates”), in which case we will require those Affiliates to comply with this Privacy Policy. ‘

(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.

(f) Corporate Restructuring. We may share your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction, or proceeding involving the sale, transfer, divestiture, or disclosure of any part of our business or assets. In the event of our insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If a third party acquires our company, business, or assets, that third party will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

(g) Social Networking Sites. Some of our Applications and Services may enable you to post content to SNSs (for example, Facebook or Twitter). If you choose to do this, we will provide information to those SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those SNSs and that it is your responsibility to review the terms of use and privacy policy of the provider of those SNSs. We are not responsible or liable for: (1) the availability or accuracy of any such SNSs; (2) the content, products, or services on or availability of any such SNSs; or (3) your use of any such SNSs.

(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).

(i) Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), littleBits may disclose Personal Data if it believes in good faith that such disclosure is necessary (1) in connection with any legal investigation; (2) to comply with applicable laws or to respond to subpoenas or warrants served on littleBits; (3) to protect or defend the rights or property of littleBits or users of the Site or Services; and/or (4) to investigate or assist in preventing any violation or potential violation of law, this Privacy Policy, or our Terms of Use.

8. Third Party Websites. The Site and one or more Services may contain links to third party websites. When you click on a link to any other website or location, you will leave the Site or applicable Service and go to another site, and a third party may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and are not responsible or liable for, these third party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third party websites or their content, or to any collection of your Personal Data after you click on links to any such third party websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are provided merely as a convenience and do not signify or imply our endorsement of, or association with, such third parties or their products, services, content, or websites. You use any such links and the products, services, and content accessed thereby at your own discretion and at your own risk.

9. Your Choices Regarding Information. You have several choices regarding the use of information on our Site and Services:

(a) Email Communications. We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see our contact information above). Despite your indicated e-mail preferences, we may send you Services-related communications, including notices of any updates to our Terms of Use or Privacy Policy.

(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.

11. Changes to This Privacy Policy. This Privacy Policy may be updated on one or more occasions for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here: http://littlebits.cc/privacy-policy and we will change the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes.