Privacy Policy

EVERYDAY BEAR, LLC PRIVACY POLICY

OUR COMMITMENT TO PRIVACY

Your privacy is important to EVERYDAY BEAR, LLC and we are committed to protecting your personal data. This Privacy Policy describes our practices in connection with information that we collect and process from you and about you in accordance with the following data protection principles:

Personal Data must:

· Be processed fairly, lawfully and transparently;

· Be collected and processed only for specified, explicit and legitimate purposes;

· Be adequate, relevant and limited to what is necessary for the purposes for which it is processed;

· Be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay;

· Not be kept for longer than is necessary for the purposes for which it is processed; and

· Be processed securely.

WHAT INFORMATION WE COLLECT

“Personal Data” is information that identifies you as a natural person or relates to an identifiable natural person. We may collect and process the following Personal Data from you:

· Personal contact information such as name, address, telephone number and email address;

· Business contact information such as business address, telephone number and email address;

· Information necessary for us to perform services for you;

· Instructions, comments, and opinions you provide when you contact us directly by email, telephone or mail or through the our website and other means

· Payment and transaction information for billing purposes.

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. We may collect and process the following Other Information:

· Browser and device information;

· Information collected through cookies, pixel tags and other technologies. 

· Demographic information and other information provided by you that does not reveal specific identities; 

· Information that has been aggregated in a manner such that it no longer reveals specific identities.

If we are required to treat Other Information as Personal Data under applicable law, then we will collect, use and disclose it for the purposes for which we collect, use and disclose Personal Data as detailed in this Policy.

HOW WE COLLECT PERSONAL DATA AND OTHER INFORMATION

We and our service providers may collect Personal Data electronically in a variety of ways, including:

· Through the software applications made available by us for use on or through computers and mobile devices (“Apps”);

· Through HTML-formatted email messages that we may send to you (“Emails”);

· Through extranet sites made available to you (“Extranet Sites”);

· Through services we provide to our customers; and

We also may collect Personal Data offline in a variety of ways, including

· When you participate in a contractual arrangement with us; 

· When you provide information in conjunction with that contractual arrangement; or 

· When you interact with us in any other way.

We also may collect Personal Data from other sources, including:

• Publicly available databases;
• Business partners, when they share the information with us; 
• Referral sources; and
• Social media platforms.

We need to collect Personal Data in order to enable us to provide services to you.  If you do not provide the information requested, we may not be able to provide our services to you. If you disclose any Personal Data relating to other people to us or to our other service providers in connection with your services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We and our other service providers may collect Other Information in a variety of ways, including through your use of our systems where permitted and an App When you use our IT systems we may collect Other Information. When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Data. If we do, we will treat the combined information as Personal Data as long as it is combined.

HOW WE USE PERSONAL DATA

We and our other service providers use Personal Data for legitimate business purposes, including:

• Providing and Receiving Services. 

o To contact other companies or organizations in connection with providing products or services, software updates and upcoming events.

o To respond to inquiries and fulfill requests from our customers and others, administer their projects and orders and manage our relationships with them.

We engage in these activities to manage our contractual relationship with others including you, to comply with a legal obligation, and/or because we have a legitimate interest in doing so.

• Providing the functionality of our Services 

o To provide our service functionality to you, such as arranging access to our systems, and providing you with related services.

o To respond to your inquiries, when you contact us electronically or otherwise (e.g., when you send us questions, suggestions, or when you request other information about our products and services).

o To send administrative information to you, such as information regarding our products and services and changes to our terms, conditions and policies, and security and administrative requirements. 

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Accomplishing our business purposes

o For data analysis, for example, to improve the efficiency of our products and services.

o For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.

o For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.

o To meet our legal and regulatory obligations.

o For enhancing, improving, or modifying our current products and services.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest in doing so.

HOW WE DISCLOSE PERSONAL DATA

We disclose Personal Data:

· To our affiliates for the purposes described in this Privacy Policy 

o You can request the list and location of our affiliates from us. Subject to local requirements, this information may be used to allow us to provide services to our other legal entities and for all the purposes outlined in this Privacy Policy.

• To third party service providers, to facilitate services they provide to us and you

o These can include providers of services such as insurance, security, services-related consulting, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

We also use and disclose your Personal Data as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

· To comply with applicable law and regulations including laws outside your country of residence. 

· To cooperate with public and government authorities, including authorities outside your country of residence.

· To cooperate with law enforcement. 

· For other legal reason such as to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. 

· In connection with a sale, merger or business transaction. 

HOW LONG WE RETAIN PERSONAL DATA

We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

· The length of time we have an ongoing relationship with you and you provide your services to us; 

· Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of our transactions or communications for a certain period of time before we can delete them); or 

· Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

WHAT SECURITY MEASURES WE USE

We have implemented internal policies and technical measures to protect Personal Data from loss, accidental destruction, misuse or disclosure. Such internal policies and technical measures include:

· The use of pseudonymisation and encryption of personal data where appropriate;

· Procedures and controls to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

· Procedures and controls to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;

· Procedures for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing; and

· Procedures to ensure that data is not accessed, except by individuals in the proper performance of their duties. 

Please note that when you use some EVERYDAY BEAR products, services, or application or post on an EVERYDAY BEAR forum, chat room, or social networking service, the personal data you share is visible to other users and can be read collected and used by them. [Such use is entirely voluntary and is not required by EVERYDAY BEAR in order to supply services to you.] You are responsible for any personal data you choose to submit in these instances and so please take care when using these features. 

SAFETY

EVERYDAY BEAR products are considered safe for everyone. With the use of essential oils always check with your doctor first. We use natural products and ingredients some being derived from coconut, cucumber, banana, rice and corn, always check with your doctor first in case of allergy. With use around animals, always check with your veterinarian prior to using our carpet refresher. Certain animals have sensitivities to scents and essential oils.

PRIVACY RIGHTS 

You have the following rights in respect of your Personal Data that we hold: 

· Right of access. You have the right to obtain confirmation of whether, and where, we are processing your Personal Data; information about the categories of Personal Data we are processing, the purposes for which we process your Personal Data and information as to how we determine applicable retention periods; information about the categories of recipients with whom we may share your Personal Data; and a copy of the Personal Data we hold about you.

· Right of portability. You have the right, in limited circumstances, to receive a copy of the Personal Data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Data to another person.

· Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete Personal Data we hold about you without undue delay.

· Right to erasure. You have the right, in some circumstances, to require us to erase your Personal Data without undue delay if the continued processing of that Personal Data is not justified.

· Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you.

· Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

If you wish to exercise one of these rights, please contact holly@everydaybear.com

California Residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories or personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request to us using the contact information provided below.

If you are under eighteen (18) years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us by using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (example: backups, etc)

This section applies to California residents only:

California Consumer Privacy Act: you have the rights listed below:

Your rights with respect to your personal data

Right to request deletion of the data. You can ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by the law, such as (but not limited to) our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed.

CalOPPA: Because we respect your privacy, we are compliant with the California Online Privacy Protection Act.

CONTACT US

If you have questions or comments about this notice you can contact us at:

Everyday Bear, LLC

PO Box 4180

Youngstown, OH 44515

holly@everydaybear.com