This Privacy Policy (this “Policy”) describes how Annabella Inc. (“Annabella” “the Company,” “we,” “us” and “our”) collects, uses, discloses and stores information you provide to us through the Annabella websites, including Annabella-pump.com (the “Site(s)”), and through other interactions with us such as email, text message, customer support system and phone communications, as well as the purchase of Annabella products including but not limited to the sale of Annabella breast pump and related products (collectively, the “Services”). This Privacy Policy shall be updated from time to time depending on the scope of Services provided and the information we collect in order to provide such services.

This Privacy Policy describes:

• Information that we collect when you interact with the Services;
• How we use and process the information that we collect;
• How we may share information with third parties;
• The security of your information.

1. User Consent.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY.  When you submit information to or through the Services, you consent to the collection and processing of your information as described in this Privacy Policy. By using the Services, you accept the terms of this Privacy Policy, our Terms of Use and consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, YOU ARE NOT AUTHORIZED TO USE THE SERVICES.

2. Information We Collect. “Personal Information”

generally means any information that can be used alone or in combination with other information to identify you as an individual, and any other information we associate with it. We collect categories of information, from different sources. We may collect the following Personal Information:

a. Profile information and other content you voluntarily provide us, which may include:

• Contact information when you register on our Site or make a purchase, such as your name, street address, phone number, and/or email address; or when you provide your email address or other contact information to receive marketing communications from us about our products.
• Content or contributions you post in a public space on the Site. This includes reviews, comments, videos and photos that you might submit. If you contact us through a social media site, we may collect your social media identifier.
• Information you provide in communications with us, such as via social media, email, text message, or our customer call center/ customer support.
• Transaction history, for instance if you make a purchase from our online store.
• Payment information, such as when you make a purchase with us and we need your billing information to process the transaction. In addition, with your consent, our third-party payment processor saves your payment card information for secure 1-click checkout.

b. Information that is passively collected when you use the Site, such as by third party analytics tools we use:

• We may record certain information about visitors to our Site, including the web request, Internet Protocol (“IP”) address, device and mobile ad identifiers, browser information, interaction with the Site, pages viewed, and other such information; we may collect similar information from emails you receive from us that can help us track which emails are opened and which links are clicked by recipients.
• We use certain cookies, pixel tags and other technologies to help us understand how you use the Site and enable us to personalize your experience on the Sites. We may ask advertisers or other third party partners to serve ads or services to your devices, which rely on cookies or similar technologies placed on our Site.
• We may detect the physical location of your device by, for example, general location information shared by your device’s IP address. We collect this information for purposes of providing you with information about promotions or new products that may be relevant to you. We may use your device’s IP address to better understand how our Site and other services and functionality are being used. Should you wish to opt out of the collection of this information, please adjust the settings of your device or web browser so that information about your physical location is not sent to us by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please consult your device settings for further information.

c. Where permitted by applicable law, we may receive information from third parties such as advertising and marketing partners, public databases, and social media platforms, to supplement the information we receive from our consumers. If we do so, this policy governs how we can use that information.

d. In addition to collecting Personal Information, we may collect information that does not identify you and is not associated with your Personal Information. We may also de-identify or anonymize information so it no longer identifies you. We can aggregate and use such information (“Aggregated Data”) to engage in marketing and other activities in a manner that is privacy sensitive since it does not include Personal Information. Aggregated Data may be derived from Personal Information, but is not considered Personal Information under the law if it cannot be used alone or in combination with other information to directly or indirectly reveal a person’s identity.

3. Cookies and Other Tracking Technologies.

What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website again, the cookie allows that site or online service to recognize your browser. Cookies may store unique identifiers, user preferences and other information.

Why do we use them? Cookies help us improve the Services by providing us with information about which parts of the Services are most popular, enabling us to analyze technical and navigational information about the Services, and helping us to detect and prevent fraud. We also use cookies and other data collection tools (such as web beacons and server logs) to help improve your experience with the Services. For example, we use Google Analytics to help us measure traffic and analyze how users use the Services (such as the pages most read, time spent, search terms and other engagement data), and to understand more about the demographics of our users and evaluate and improve the user experience and the Sites. These tools use cookies to collect standard internet log information and visitor behavior information. To learn how to turn off cookies, please see below.

4. Important Notes About your Opt-Out:

a. If you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us across the Internet, but the ads may be less relevant to you and your interests.

b. Interest-based advertising opt-outs work by saving cookies in your browser that tell the various ad partners that you have opted-out. Because cookies are generally browser-specific, your choice will only apply to the web browser from which you opt-out. You must opt-out from each web browser from which you do not want interest-based advertising (and this may involve different devices, if you use more than one). If you delete or clear your browser’s cookies, you will need to opt-out again.

5. How Information is Used.

We may use the information we collect for purposes that include:

a. to provide the Services to you, including processing transactions and sending related communications;

b. to operate, improve, and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;

c. for customer service, security, to detect fraud or illegal activities and for archival and backup purposes in connection with the provision of the Services;

d. for research and analysis purposes, such as determining trends in consumption of our products and determining where our products may be in demand;

e. to communicate with users where permitted by applicable law;

f. to permit you to participate in social sharing, including social media feeds;

g. to fulfill your requests, such as those relating to ordering and payments;

h. to comply with applicable law and legal process;

i. purposes we disclose to you at the time we collect the information; and

j. to enforce our Terms of Use or other applicable policies.

The Information provided to us will be stored in the Company’s databases only for the time required to fulfil the purposes for which the Information is collected, as will be deemed necessary by the Company at its sole discretion, and in any case – in accordance with applicable law. It is hereby clarified that anonymized information may remain on the Company’s servers indefinitely and the Company may use such information, among other things, for analytical and statistical purposes.

6. Sharing of Information.

We may share or disclose information as described at the time information is collected or as follows:

With Third Party Service Providers Performing Services on Our Behalf.  We share information, including personal information, with our service providers to perform the functions for which we engage them. For example, we may use third parties such as Shopify, Klaviyo and Yotpo, to host the Services, provide data analysis and research services, send out email updates about the Services, provide marketing, analytics and advertising services for us, remove repetitive information from our user lists, and to help us deliver our products and services to customers and process payments. Such use will be governed by such third parties’ privacy policies.

For Legal Purposes.  We and our U.S. service providers also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions in accordance with applicable privacy laws. We and our service providers will disclose personal information as we deem necessary to respond to a subpoena, warrant, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. We may also share personal information as required to pursue available remedies or limit damages we may sustain.

7. Corporate Changes.

We may transfer information, including your personal information, in connection with a proposed or completed merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part) provided that the information will continue to be bound by this Privacy Policy or the privacy policy of the purchasing entity. U.S. State Law Requirements

Some U.S. state privacy laws such as the California Consumer Privacy Act (CCPA) and Virginia Consumer Data Protection Act (VCDPA) require specific disclosures for state residents.

The United States Regional Privacy Notice (“U.S Notice”) attached hereto as Exhibit A supplements our Privacy Policy.

This US Notice is for individuals residing in certain U.S states and is designed to help you better understand how we collect, use, and disclose your personal information and, depending on how you use the Sites, where you reside, how to exercise available rights under various applicable privacy laws in the US, including, but not limited to, the CCPA, the VCDPA, the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, and the Utah Consumer Privacy Act (collectively, the “US Privacy Laws”).

8. Security and Retention of Your Information.

We employ reasonable security measures designed to protect the security of personal information submitted through the Services. However, the security of personal information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password-protected or secure areas of any of our Services. In order to protect us, you, and your data, we may suspend your use of the Services, without notice if any breach of security is suspected. Access to and use of password-protected and/or secure areas of the Services are restricted to authorized users only. Unauthorized access to such areas is prohibited.

9. Links to Other Sites.

The Services may contain links and widgets related to third-party websites and services, such as social networks (a “Third Party Service”), with which we have no affiliation. A link to or other availability of any Third Party Service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a Third Party Service, you are subject to the privacy policy and practices of the third party that operates the Third Party Service and not this Privacy Policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.

10. Choices with Your Personal Information and Opting Out.

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

a. Cookies and Other Tracking Technologies. Web browsers typically allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Mobile devices may also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Services.

b. Google Analytics. If you would like to opt-out from the processing of your information by Google Analytics, you may use Google Analytics opt-out browser add-on designed for this purpose at https://tools.google.com/dlpage/gaoptout.

c. Email and Text Message Marketing Communications. If you do not wish to receive marketing or promotion messages from us, you can opt out by following the instructions using the “Unsubscribe” link on any email you receive from us or by replying STOP to any text message. If you opt out of receiving such communications, note that we may continue to send you non-promotional transactional or informational emails (such as order confirmation emails or emails about changes to our legal terms).

Please note that making such requests does not ensure complete or comprehensive removal of your content. For example, we may retain the information for our own internal records in accordance with the terms of this Privacy Policy.

11. Effective Date and Changes to Privacy Policy.

The Effective Date of this Privacy Policy is set forth at the top of this webpage. We may change this Privacy Policy from time to time at our discretion. Changes will be posted to this webpage. We encourage you to return to this webpage frequently so that you are aware of our current privacy practices. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

12. Non-U.S. Visitors.

All personal information we collect through the Services is currently processed in the United States by us or by a service provider acting on our behalf. When you provide personal information to us through the Services, your personal information will be transferred to and processed in the United States.

13. Children.

We do not knowingly collect or maintain personal information from any person under the age offifteen. No parts of our Services are directed to or designed to attract anyone under the age offifteen.

14. Do Not Track.

The Services do not support Do Not Track with respect to the Services at this time. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit www.donottrack.us.

15. Access, Correction and Deletion.

You may request access to, correction or deletion of other personal information in our records (subject to limitations under applicable law) by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to personal information records.

Under US Privacy Laws, you may also designate an authorized agent to make these requests on your behalf. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued ID, to verify your identity before processing your request to protect your information.

16. Notices.

Please send all questions, comments and notices regarding this Privacy Policy to our Privacy Leader at annabella@annabella-pump.com.

17. Contact Us

If you have any questions or concerns about Annabella’s privacy policy and practices (or the privacy practices of our service providers), please contact our Privacy Officer at annabella@annabella-pump.com.

U.S. Privacy Notice

This Privacy Notice (“Privacy Notice”) supplements Annabella’s Privacy Policy and applies to personal information Annabella collects online about consumers residing in the U.S. This Privacy Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

1. Notice of Collection and Use of Personal Information.

We may collect the following categories of personal information about you:

• Identifiers: information that identifies you, including your legal name, email address, unique personal identifiers (such as a device identifier and/or IP address).
• Other Records: such as phone number, billing address, or credit or debit card information, and any other personal information covered by Cal. Civ. Code §1798.80(e) (which may overlap with other categories listed here).
• Demographic Information: such as your age or gender, or, where you have provided such information to Annabella voluntarily, demographic information about your race, ethnicity, sexual orientation, or gender identity, provided in connection with market research or marketing campaigns we conduct. This category includes information that may qualify as protected classifications under other California or federal laws.
• Commercial Information: including purchases, products sold, and/or your interaction with the Services.
• Internet or Other Network Activity: information including your interactions with our Services and what led you to our Services (including web/mobile traffic related information); device type and/or identifier, operating system and version, browser type and settings and cookie-related data (e.g., cookie ID).
• Sensory Information: data categorized as visual data, such as pictures or videos posted on our Service.
• Geolocation Data: your general location provided through location-enabled services such as WiFi and GPS or precise location information, with your consent, when enabled through one of our mobile applications or from your mobile device settings.
• Inferences: inferences based on personal information about you, including your interests, preferences, and favorites; inferred information about your demographic category used to create marketing segments or profiles.

2. Sources and Purposes for Our Collection.

We collect the categories of personal information described in this Privacy Notice from the sources described in Section 2 of the Annabela Privacy Policy, which includes collecting information directly from you, your devices, and our partners. The sources of this data include you and the devices you use, including computers, phones, and other web-connected devices you use to access our Site; advertising networks; service providers (including internet service providers); social networks or other public sources, marketing and business partners, and our vendors and suppliers. We use these categories of personal information for our business and commercial purposes as described throughout the Annabella Privacy Policy.

3. Sale or Sharing of Personal Information.

We do not sell your personal information in exchange for monetary compensation. We may share your personal information by allowing certain third parties (such as online advertising services) to collect personal information through automated technologies on our Sites and Apps for targeted (cross-context behavioural) advertising purposes. This kind of sharing may be considered a “sale” under California law, and you have a right to opt out of it.

4. Disclosure of Personal Information for a Business Purpose

We share personal information with service providers, contractors, and other third parties. The following table lists the categories of personal information that have been disclosed for a business purpose and the categories of recipients with whom we may have shared your information. Please note that not every one of the following categories may apply to your information.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

• Identifiers.
• Other records.
• Commercial information.
• Internet or other electronic network activity information.
• Geolocation data.
• Inferences derived from other personal information.
• Other information you provide; and
• Sensitive personal information, which may include:
• Government-issued identifiers, including social security, driver’s license, state identification card, or passport number.
• Your account access credentials (such as account log-in, financial account, debit or credit card number in combination with any required security access code, password, or credentials allowing access to an account).
• Your device’s precise location.
• Information voluntarily disclosed that may reveal certain characteristics about you such as your racial or ethnic origin or sexual orientation.

RECIPIENTS OF PERSONAL INFORMATION

• Our corporate affiliates.
• Business partners.
• Advertisers and marketing vendors.
• Analytics providers.
• Social Networks.
• Law enforcement or other third parties in connection with legal requests, to comply with applicable law or to prevent harm.

5. Exercising Your Rights.

Please see section 13 of the Annabella Privacy Policy for information about your privacy rights and how to exercise them. In certain states, you may have the right to appeal our decision regarding a request related to these rights. If you wish to appeal a decision, please contact annabella@annabella-pump.com.

Shine the Light.

California residents are entitled to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. Annabella does not share any personal information with third parties for their own direct marketing purposes, unless you otherwise consent to it and/or direct it. If you have questions about these practices, or would like to make a request, you can contact us through one of the channels listed in the “Contact” section of our Privacy Policy. In your request, please 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 labelled or sent properly, or that do not have complete information.