HAPPY 2ND BIRTHDAY, INC.
PRIVACY POLICY

Happy 2nd Birthday, Inc. (“Happy 2nd Birthday,” “we,” “us,” or “our”) is committed to respecting your privacy rights, and we welcome you to https://www.happy2ndbirthday.com and all of our associated sites and mobile applications (collectively, the “Site”). This privacy policy (“Privacy Policy” or “Policy”) applies to all of Happy 2nd Birthday’s Site visitors, customers, and employees (“Consumer(s)”) with regard to our Site, browsing our Site, purchasing our products, and maintaining accounts on our Site (collectively, “Services”). This Privacy Policy describes the personal information (defined below) that we collect, use, and disclose from our Consumers through providing our Services online and offline, the steps we take to protect such information, and the rights our Consumers have regarding their personal information. This Policy is incorporated into and is subject to Happy 2nd Birthday’s Terms of Service. Before using our Service or submitting any personal information to Happy 2nd Birthday, please review this Privacy Policy carefully and contact us if you have any questions. By using our Service, you accept the privacy practices described in this Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use our Service.

  1. COLLECTION OF PERSONAL INFORMATION

    Happy 2nd Birthday collects information that alone or in combination with other information in our possession could be used to identify our Consumers (“Personal Information”). Certain laws, such as the California Consumer Privacy Act of 2018 (“CCPA”), require that we disclose certain information about the categories of Personal Information we collect about our Consumers from both our online and offline practices. Happy 2nd Birthday does not sell Personal Information to any third parties for monetary considerations, although Happy 2nd Birthday may provide such information to its authorized third parties in order to conduct its ordinary course of business. All authorized third parties must also implement and maintain reasonable security procedures and practices to protect Consumer Personal Information in compliance with this Policy. Furthermore, we may release Consumer Personal Information when we believe such release is appropriate to comply with state or federal laws.

  2. HOW HAPPY 2ND BIRTHDAY OBTAINS PERSONAL INFORMATION

    Happy 2nd Birthday may obtain Personal Information either directly from you (through account registration and direct input of information on our Site such as name, email address, mailing address, telephone number, personal or company titles, reviews, photos, credit card information, login information, etc.) or indirectly from you (by tracking actions you take on our website or browsing our website, such as IP addresses, domain information, geolocation information, etc.). Happy 2nd Birthday may also collect Personal Information through our social media pages, such as Instagram, Medium, Facebook, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information, analytics regarding the use of our Social Media Pages, and information from your public profile, if the third-party service and your account settings allow for such sharing. The information that we receive will depend on the policies and your account settings with the third-party services. Additionally, Happy 2nd Birthday may also gather anonymous “traffic data” that does not personally identify you, but may be helpful for marketing purposes or improving our Services.

    2.1 User-provided Information. When you use the Service, you may provide, and we may collect Personal Information. Examples of Personal Information include name, email address, mailing address, mobile phone number, and credit card or other billing information. Personal Information also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Information in various ways on the Service. For example, when you register for an Account, use the Service, post product reviews, interact with other Consumers of the Service through communication or messaging capabilities, or send us customer service -related requests.

    2.2 “Automatically Collected” Information. When a Consumer uses the Service, we may automatically record certain information from the Consumer’s device by using various types of technology, including cookies, “clear gifs” or “web beacons.” This “automatically collected” information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the Consumer views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Consumer’s interaction with email messages, such as whether the Consumer opens, clicks on, or forwards a message. This information is gathered from all Consumers.

    2.3 Integrated Services. You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google account, or otherwise have the option to authorize an Integrated Service to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.

    2.4 Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.

  3. CATEGORIES OF INFORMATION COLLECTED

    Happy 2nd Birthday collects certain categories of Consumer Personal Information, but we do not sell Consumer Personal Information subject to certain privacy laws, including the CCPA. Certain laws, such as the CCPA, require that Happy 2nd Birthday releases the categories of Personal Information that Happy 2nd Birthday collects on Consumers in the past twelve (12) months, and the purposes of their collection (see also section “How We Use the Information We Collect”). The following is a table of all the categories of Personal Information that Happy 2nd Birthday may collect, some examples of each category, and the purpose of its collection:

    Category Examples Purpose of Collection
    Identifiers A real name, title, alias, postal address, unique personal identifiers, online identifiers, internet protocol address, MAC address, email address, account name, telephone number, social media handles, username, user content (for example comments, reviews, or posts), financial information including credit card information, or other similar identifiers.
    • Verify your identity
    • Process your request/ business transaction
    • Provide support, personalize, and develop our Services and products
    Protected Classification Characteristics Age, sex, military or veteran status, national origin.
    • Verify your identity
    • Check your qualifications
    • Process your request/ business transaction
    • Create, maintain, customize, and secure your registration, Account, forms, or other documents
    • Respond to law enforcement requests as applicable
    Physical Characteristics Skin type, eye color, hair type and color, facial images (for reviews, or certain applications to improve our Services).
    • Provide support, personalize, and develop our Services and products
    • For testing, research, analysis, and product development, including to develop and improve our products and Services
    Audio and Visual Information Recording of your voice or videos you send when communicating with customer service.
    • Provide support, personalize, and develop our Services and products
    Internet or Network Activity Activity including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisements.
    • Marketing and promotional services
    • Automatic collection of domain names, MAC addresses, and IP addresses
    • For testing, research, analysis, and product development, including to develop and improve our products and Services
    Employment Related Information Current or past job history, and credentialing information, citizenship, and background checks.
    • Verify your identity
    • Check your qualifications for employment purposes
    • Process your request/ business transaction
    Geolocation Information Physical location of you or your device
    • Verify your identity
    • Check your qualifications for employment purposes
    • Process your request/ business transaction
  4. HOW WE USE THE INFORMATION WE COLLECT

    Besides the purpose of collection listed above, we use the information that we collect in a variety of ways to provide our Service and operate our business, including the following:

    4.1 Operations

    We use Personal Information to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to Consumers of the Service.

    4.2 Improvements

    We use the information to understand and analyze the usage trends and preferences of our Consumers, to improve the Service, and to develop new products, services, features, and functionality.

    4.3 Communications

    We may use a Consumer’s email address or other Personal Information to contact Consumer: (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Student Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”

    4.4 Cookies and Tracking Technologies

    We use automatically collected information and other information collected on the Service through cookies and similar technologies (e.g. web beacons, pixel tags, SDKs, etc.) to: (i) personalize our Service, such as remembering a Consumer’s information so that the Consumer will not have to re-enter it during a visit or on subsequent visits to our Site; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.

    4.5 Analytics

    We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Site and create Consumer navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Consumers’ activity on our Site. For more information, see Google Analytics Privacy and Data Sharing.

    We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Consumers.

  5. TO WHOM WE DISCLOSE INFORMATION

    Except as described in this Policy, we will not intentionally disclose the Personal Information that we collect or store on the Service to third parties without the consent of the applicable Consumer. We may disclose information to third parties if you provide us consent to do so, as well as in the following circumstances:

    5.1 Unrestricted Information

    Any information that you voluntarily choose to include in a public area of the Service, such as a public profile page, will be available to any Consumer who has access to that content.

    5.2 Service Providers

    We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Information as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

    5.3 Non-Personally Identifiable Information

    We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Consumers’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.

    5.4 Law Enforcement, Legal Process and Compliance

    We may disclose Personal Information or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

    We also reserve the right to disclose Personal or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

    5.5 Change of Ownership

    Information about Consumers, including Personal Information, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the Consumer Personal Information commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

    Consumer Personal Information may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the Consumer Personal Information commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

  6. YOUR CHOICES

    6.1 Access, Correction, Deletion

    We respect your privacy rights and provide you with reasonable access to the Personal Information that you may have provided through your use of the Services. If you wish to access or amend any Personal Information we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.

    You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Service. Please note that while any changes you make will be reflected in active Consumer databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

    You may decline to share certain Personal Information with us, in which case we may not be able to provide to you some of the features and functionality of the Service.

    At any time, you may object to the processing of your Personal Information, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Happy 2nd Birthday at privacy@happy2ndbirthday.com. You also have a right to lodge a complaint with data protection authorities.

    6.2 Navigation Information

    We may collect navigation information about your visit to our Site. You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.

    6.3 Opting out from Commercial Communications

    If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.

    Please be aware that if you opt-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Services.

  7. THIRD-PARTY SERVICES AND INTEGRATED SERVICES

    The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service, although third-party sites or services should have their own privacy and security policies in place. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

    You may be given the option to access or register for our Services through the use of your login information (username and passwords) for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google account, or otherwise an Integrated Service to provide Personal Information or other information to us. By authorizing us to connect with an Integrated Service, you may authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture, URL, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.

  8. CALIFORNIA CONSUMER PRIVACY RIGHTS

    In this section, we provide information for California residents, as required under California privacy laws, including the CCPA, which requires that we provide California residents certain specific information about how we handle their Personal Information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under the CCPA.

    8.1 Notice before Collection. Happy 2nd Birthday is required to notify California residents, at or before the point of collection of their Personal Information, the categories of Personal Information collected and the purpose for such information used (please see Section “Categories of Information Collected”).

    8.2 California Residents’ Rights. California law grants California residents with certain rights and imposes restrictions on particular business practices as set forth below:

    • Right to Know if Personal Information is Collected, Sold, or Disclosed: California Residents have the right to know if Happy 2nd Birthday collects, sells, or discloses their Personal Information. HAPPY 2ND BIRTHDAY DOES NOT SELL PERSONAL INFORMATION. Happy 2nd Birthday may disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to: (1) conform to the edicts of the law or comply with any legal process served on us, our subsidiaries, or affiliates; (2) protect and defend our rights or property, or those of our consumers; or (3) under exigent circumstances to protect the safety of the public or our Consumers. You may make a request to know what Personal Information is collected or disclosed about you by contacting us (see Section below “How to Make a Request to Know or Delete Personal Information”).
    • Right to Request Deletion of Personal Information: California residents have the right to request that Happy 2nd Birthday delete any of their Personal Information that Happy 2nd Birthday collects, at no additional charge, subject to certain exemptions. Happy 2nd Birthday will delete (and direct our service providers to delete) your Personal Information from its records, unless an exemption applies. Happy 2nd Birthday may deny your deletion request if retaining the information is necessary to: (1) comply with legal obligations; (2) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (3) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (4) complete a transaction for which Happy 2nd Birthday collected Personal Information, provided a good or service that was requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract with you; and (5) other exemptions listed under the CCPA. You may make a request to delete your Personal Information by contacting us (see Section below “How to Make a Request to Know or Delete Personal Information”).
    • Right to Non-Discrimination for Exercising Privacy Rights: Happy 2nd Birthday will not discriminate against you for exercising any of your consumer privacy rights, including those rights under the CCPA. Unless otherwise permitted by the CCPA, if you exercise any of your privacy rights, Happy 2nd Birthday will not: (1) deny you of goods or service; (2) charge you different prices or rates for goods or services; (3) provide you a different level or quality of goods or services; or (4) suggest that you may receive a different price or rate of goods or services or a different level of goods or services.
    • Right to Opt-Out of Sale of Personal Information. California residents have the right to opt-out of the sale of their Personal Information. However, HAPPY 2ND BIRTHDAY DOES NOT SELL PERSONAL INFORMATION COLLECTED FROM ITS SITE OR OFFLINE.

    8.3 How to Make a Request to Know or Delete Personal Information. If you are a California resident, you may make a consumer request to know or request to delete Personal Information, and we will get back to you within forty-five (45) days of receiving your request. The time frame for us to provide the required information may be extended once by an additional 45 days when reasonably necessary, provided you are given notice of the extension within the first 45-day period. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable request on behalf of your minor child. If you use a legally authorized agent to make the consumer request, we reserve the right to require verification of your authorized agent’s identity, which may include: (1) verification of your identity; (2) power of attorney pursuant to California Probate Code sections 4000-4545 or other sufficient proof in our discretion to establish your agent’s authority; and (3) your authorized agent’s valid government issued identification or proof of identity acceptable to use at our sole discretion.

    You may make a request by contacting us at (see also section “How to Contact Us”):

    8.4 Denial of Request. Happy 2nd Birthday may deny your request to know or request to delete Personal Information if your information is not maintained in a searchable or reasonably accessible format, or if your personal information is maintained solely for legal or compliance purposes. Further, your request may be denied for any of the exceptions listed under the Section “Right to Request Deletion of Personal Information.” If your request is denied, Happy 2nd Birthday will inform you and explain the basis for denial, unless prohibited from doing so by law.

  9. INTEREST BASED ADVERTISING

    Interest based advertising is the collection of information from different sources across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertisement based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.

    We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in Happy 2nd Birthday’s products or Services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.

    These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners, which measure the effectiveness of certain advertisements; and (3) business partners, which collect information when a person views or interacts with one of their advertisements.

    In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.

    The information we or third party collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.

    We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide more useful and relevant ads – for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.

    Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.

    Visitors may opt out of receiving interest based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all – of the interest-based advertising activities in which we or third parties engage.

  10. DO NOT TRACK POLICY

    California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signal. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.

    In the meantime, you may opt out of receiving interest-based advertising from advertising networks that may be delivered on our platform and other websites by visiting the following websites. If you want to opt out of this online behavioral advertising, visit the following sites: http://www.aboutads.info/consumers and http://www.networkadvertising.org.

    This will opt you out of many – but not all – of the interest-based advertising activities in which we or third parties engage. Choices you make may be browser and device specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices. Other third-party Sites provide visitors with the ability to opt-out of receiving interest-based ads on their Sites that you need to control through your settings on that Site. For example, to opt out of Google’s use of your online behavior for advertising purposes, visit Google’s Ad Settings page.

  11. THIRD PARTY COOKIES

    Certain states, including California, require that operators of websites and online services disclose whether other third parties may collect Personal Information about an individual’s online activities from their site or service. We allow third parties with which we have a separate agreement to use cookies and other technologies to collect information about your use of the Site. These third parties include (1) business partners, which collect information when you view or interact with one of their advertisements on the Site; and (2) advertising networks, which collect information about your interests when you view or interact with one of their advertisements.

    The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on this Site and on other sites across the Internet tailored to your apparent interests.

    The business partners and advertising networks that serve interest-based advertisements on the Services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they may reuse this small amount of information on other sites or services.

    We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Notice. Other than as discussed in this document, we have no control over these third parties.

  12. TYPES OF COOKIES USED ON THE SITE:
    1. Strictly necessary/essential cookies – These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided. These cookies don’t collect information that identifies a visitor.
    2. Performance cookies – These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
    3. Functionality cookies – These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
    4. Behaviorally targeted advertising cookies – These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.
  13. MINORS AND CHILDREN’S PRIVACY

    Our Service is not directed to children who are under the age of 13. Happy 2nd Birthday does not knowingly collect Personal Information from children under the age of 13. If we learn that we collected Personal Information from a child under the age of 13, without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an Account on the Service, then you may alert us at privacy@happy2ndbirthday.com (see also section “How to Contact Us”) and request that we delete that child’s Personal Information from our systems.

  14. DATA SECURITY

    We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Information.

    However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Information has been compromised, please contact us as set forth in the “How to Contact Us” section.

    If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

  15. DATA RETENTION

    We only retain the Personal Information collected from a Consumer for as long as the Consumer’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  16. SETTINGS

    Although we may allow you to adjust your privacy settings to limit our access to certain Personal Information, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.

  17. DATA TRANSFER

    We may transfer, process and store Personal Information we collect through the Services in centralized databases and with service providers located in the U.S. The U.S. may not have the same data protection framework as the country from which you may be using the Services. When we transfer Personal Information to the U.S., we will protect it as described in this Privacy Policy.

  18. DATA CONTROLLER AND DATA PROCESSOR

    Happy 2nd Birthday does not own, control or direct the use of any Personal Information stored or processed by a Consumer via the Service. Only Consumers are entitled to access, retrieve and direct the use of such Personal Information.

    Happy 2nd Birthday does not act in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”) and does not have the associated responsibilities under the GDPR. Happy 2nd Birthday should be considered only as a processor on behalf of Consumers as to any Personal Information that is subject to the requirements of the GDPR. Except as provided in this Privacy Policy, Happy 2nd Birthday does not independently cause Personal Information stored in connection with the Services to be transferred or otherwise made available to third parties, except to third party subcontractors who may process such data on behalf of Happy 2nd Birthday in connection with Happy 2nd Birthday’s Services. Such actions are performed or authorized only by the applicable Consumer.

    The Consumers is the data controller under the Regulation for any Personal Information, meaning that such party controls the manner such Personal Information is collected and used as well as the determination of the purposes and means of the processing of such Personal Information.

    Happy 2nd Birthday is not responsible for the content of the Personal Information or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Consumer nor is Happy 2nd Birthday responsible for the manner in which the Consumer collects, handles disclosure, distributes or otherwise processes such information.

  19. CHANGES AND UPDATES TO THIS POLICY

    Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

  20. CHANGES AND UPDATES TO THIS POLICY

    Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

  21. HOW TO CONTACT US

    Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at privacy@happy2ndbirthday.com.

    Last update: October 15, 2020